Case Digest (G.R. No. L-76710)
Facts:
The case involves Antonio Ong, Sr. as the petitioner and Henry M. Parel, in his capacity as Regional Director of the Ministry of Labor and Employment, along with several complainant workers, as respondents. The events leading to this case began on July 28, 1986, when Rowena Reteracion, president of the Mansion House Genuine Labor Union, filed a request for inspection of Ong's restaurant located at No. 11, J. M. Basa Street, Iloilo City. The request was based on allegations that Ong had failed to comply with various labor standards, including the payment of minimum wage, emergency cost of living allowance, 13th month pay, and 5-day incentive leave pay. An inspection was conducted on July 30, 1986, during which Ong was unable to present his business records, claiming they were with his accountant. He was given until August 4, 1986, to present these records.
A second visit occurred on August 4, 1986, but Ong again failed to provide the requested documents. Subsequently, a...
Case Digest (G.R. No. L-76710)
Facts:
Background and Parties Involved:
The petitioner, Antonio Ong, Sr., owns the Mansion House Restaurant in Iloilo City. The respondents include Henry M. Parel, the Regional Director of the Ministry of Labor and Employment (MOLE), and thirteen employees of the restaurant.
Inspection and Complaints:
On July 28, 1986, Rowena Reteracion, president of the Mansion House Genuine Labor Union, filed a request for inspection of the restaurant regarding alleged violations of labor standard laws, including failure to pay minimum wage, emergency cost of living allowance, 13th month pay, and 5-day incentive leave pay.
Execution of Inspection:
On July 30, 1986, MOLE representatives conducted an on-the-spot inspection but were unable to access the petitioner’s business records, which were allegedly with his accountant. The petitioner was given until August 4, 1986, to produce the records. Thirteen employees provided affidavits supporting the claims of labor law violations.
Non-Compliance with Subpoena:
On August 4, 1986, MOLE officers returned for the records, but the petitioner again failed to comply. On August 7, 1986, a subpoena duces tecum was issued, requiring the petitioner to submit the requested records. Instead of complying, the petitioner sent a letter on August 12, 1986, seeking clarification about the inspection's basis.
Final Order and Execution:
On October 7, 1986, the Regional Director issued a Final Order for Compliance, directing the petitioner to pay P254,841.26 to the thirteen employees for underpayment and non-payment of wages and benefits. The petitioner filed a motion for reconsideration, which was denied on November 18, 1986. A writ of execution was issued on December 12, 1986, and the petitioner issued a postdated check for the amount.
Issue:
- (Unlock)
Ruling:
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Ratio:
Jurisdiction over Money Claims:
Under Article 217 of the Labor Code, labor arbiters have original and exclusive jurisdiction over money claims arising from employer-employee relationships. The Regional Director’s authority under Article 128(b) of the Labor Code is limited to enforcing labor standards and does not extend to adjudicating money claims.Limitation on Regional Director’s Powers:
MOLE Policy Instruction No. 7 limits the Regional Director’s authority to enforcing labor standards for claims not exceeding P100,000. This does not grant the Regional Director the power to adjudicate money claims.Due Process Observed:
The petitioner was given multiple opportunities to present his records and respond to the claims but failed to do so. The essence of due process—having a “day in court”—was satisfied, as the petitioner was afforded the opportunity to be heard.