Title
Lozon vs. National Labor Relations Commission
Case
G.R. No. 107660
Decision Date
Jan 2, 1995
A certified public accountant files a complaint for illegal dismissal against an airline company, but the Supreme Court rules that the National Labor Relations Commission does not have jurisdiction over the case, and the issue falls under the exclusive jurisdiction of the Securities and Exchange Commission.
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Case Digest (G.R. No. 107660)

Facts:

  • Ramon C. Lozon, a certified public accountant, was the Senior Vice-President for Finance at Philippine Airlines, Inc. (PAL).
  • His employment was terminated on December 19, 1990, during the "two-billion-peso PALscam" scandal.
  • Lozon had been employed at PAL since August 23, 1967, accumulating over twenty-three years of service.
  • His dismissal was associated with allegations of misconduct involving high-ranking officials, including himself, as noted by board member Solicitor General Francisco Chavez.
  • An investigation was initiated by then-President Corazon C. Aquino, resulting in Lozon's preventive suspension.
  • He faced charges of gross inefficiency and dereliction of duty due to financial mismanagement.
  • On June 26, 1991, Lozon filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC), seeking reinstatement, back wages, fringe benefits, and damages.
  • The Labor Arbiter ruled in favor of Lozon on March 17, 1992, ordering reinstatement and awarding damages.
  • PAL contested the NLRC's jurisdiction, asserting that the case fell under the exclusive jurisdiction of the Securities and Exchange Commission (SEC).
  • The NLRC subsequently dismissed Lozon's case, prompting a petition for certiorari to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the NLRC's dismissal of the case.
  • The Court confirmed that the SEC has original and exclusive jurisdiction over intracorporate matters concerning the dismissal of corporate officers.
  • PAL was not barre...(Unlock)

Ratio:

  • The ruling was grounded in Presidential Decree No. 902-A, which grants the SEC exclusive jurisdiction over intra-corporate relations, including the appointment and removal of corporate officers.
  • Lozon's role as Senior Vice-President classified him as a seni...continue reading

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