G.R. No. 58494 - Philippine National Oil Co.-Energy Development Corp. vs. Leogardo

Philippine National Oil Company-Energy Development Corporation (PNOC-EDC) is a subsidiary of the Philippine National Oil Company (PNOC).
PNOC-EDC initiated action by filing a Petition for Certiorari to challenge the jurisdiction of the Ministry of Labor and Employment.

On December 19, 1977, during a Christmas party at the petitioner’s camp in Uling, Cebu, private respondent Vicente D. Ellelina allegedly committed an act amounting to "Alarm or Public Scandal."
The incident involved Ellelina attempting to grab an armalite rifle from a PC Officer after a dispute over a raffle prize, despite the warning shots fired by the officer.

On January 20, 1978, PNOC-EDC filed a clearance application with the Ministry of Labor and Employment, Regional Office No. VII, in Cebu City, seeking to terminate/dismiss Ellelina based on the criminal act.
The Regional Office (MOLE) initially granted the clearance for dismissal but later reversed its decision by ordering the reinstatement of Ellelina without loss of seniority rights and with allocation of backwages from February 1, 1978, until his actual reinstatement.
Petitioner PNOC-EDC appealed the revocation of clearance and the subsequent reinstatement order.

PNOC-EDC asserted that under Article 277 of the Labor Code, the Ministry of Labor should have no jurisdiction over it, as it is a government-owned or controlled corporation.
It maintained that Ellelina’s dismissal was valid and justifiable due to the commission of a crime.

Public respondent contended that PNOC-EDC, though a subsidiary of a government entity, is organized as a private corporation under the Corporation Law and registered with the Securities and Exchange Commission, thereby placing it within the ambit of the Labor Code.
They further argued that PNOC-EDC was estopped from contesting the Labor Department’s jurisdiction since it had availed itself of the clearance process.
The respondent also maintained that dismissal was an excessively harsh penalty given the circumstances.

Whether or not PNOC-EDC, by virtue of being a subsidiary of the government-owned PNOC, is governed by the Labor Code or should instead be under the Civil Service Law.
Whether the Ministry of Labor’s exercise of jurisdiction over PNOC-EDC is valid.

Whether the dismissal of private respondent Ellelina was valid and just under the circumstances considering the alleged commission of a crime at a company event.
Whether the penalty of dismissal, as applied, was commensurate with the offense in question.