Lumanta vs. National Labor Relations Commission

Facts:

The case is Luz Lumanta, et al., G.R. No. 82819, February 08, 1989, the Supreme Court Third Division, Feliciano, J., writing for the Court. Petitioners are Luz Lumanta and fifty-four other retrenched employees; respondents are the National Labor Relations Commission (NLRC) and Food Terminal, Inc. (FTI); the Labor Arbiter below was Isabel P. Oritiguerra.

On 20 March 1987 petitioners filed a complaint with the Department of Labor and Employment (later processed before the Labor Arbiter) against FTI for unpaid retrenchment or separation pay; the complaint was later amended to add claims for underpayment of wages and non-payment of emergency cost of living allowances (ECOLA). FTI moved to dismiss for lack of jurisdiction, arguing that as a government-owned or controlled corporation (GOCC) its employees are governed by the Civil Service Law and that employment disputes fall within the jurisdiction of the Civil Service Commission, not the Department of Labor and Employment or the NLRC.

Petitioners countered that, despite government ownership or control, FTI retained indicia of a private corporation: it was organized under the general Corporation Code (previously the Greater Manila Food Terminal Market, Inc.), hires directly without CSC approval, its personnel were covered by the Social Security System rather than GSIS, and it was not one of the GOCCs "with original charter" under the 1987 Constitution. Letter of Instruction No. 1013 (19 April 1980) had included FTI among GOCCs, and the record showed that the government did not own 100% of its capital stock.

On 31 August 1987 the Labor Arbiter issued an order dismissing the complaint for lack of jurisdiction, holding the case governed by the Civil Service Law. On 18 March 1988 the NLRC affirmed the Labor Arbiter's dismissal. Petitioners then filed a Petition for Certiorari with the Supreme Court seeking to...(Pro-only)

Issues:

• Did the Labor Arbiter and the National Labor Relations Commission act without or in excess of jurisdiction in dismissing petitioners' complaint for lack of jurisdiction?

• Under the 1987 Constitution, do labor-law claims against a government-owned or controlled corporation that lacks an original charter fall within the jurisdiction of the Department of Labor and Employment (and are governed by the Labor Code) rather than the Civil Servi...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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