Case Digest (G.R. No. 79182)
Facts:
PNOC-Energy Development Corporation v. National Labor Relations Commission (Third Division) and Danilo Mercado, G.R. No. 79182, September 11, 1991, the Supreme Court Second Division, Paras, J., writing for the Court.Private respondent Danilo Mercado was first employed by petitioner Philippine National Oil Company–Energy Development Corporation (PNOC‑EDC) on August 13, 1979 and held various clerical positions at its Cebu office until his transfer to PNOC‑EDC’s Palimpinon, Dumaguete establishment on September 5, 1984. Mercado was dismissed on June 30, 1985; his last reported pay was P1,585.00 basic plus P800.00 living allowance.
PNOC‑EDC charged Mercado with serious dishonesty and violations of company rules. The dishonesty allegations arose from (a) an April 12, 1985 purchase of 1,400 nipa shingles from Mrs. Leonardo Nodado for P1,680.00, where Mercado allegedly paid only P1,000.00 and appropriated P680.00; (b) failure to report a P70.00 discount on that purchase; and (c) a March 28, 1985 payment of P20.00 to a stamp maker for a P28.66 job, allegedly appropriating P8.66. PNOC‑EDC also alleged unauthorized absences on June 5 and June 15, 1985.
On September 23, 1985 Mercado filed before the NLRC Regional Arbitration Branch No. VII (Case No. RAB‑VII‑0556‑85) a complaint for illegal dismissal, retirement benefits, separation pay, unpaid wages and related claims. Mercado filed his position paper on December 16, 1985; PNOC‑EDC filed a Position Paper/Motion to Dismiss on January 15, 1986 contending the Labor Arbiter and the NLRC lacked jurisdiction because PNOC‑EDC, as a government‑owned or controlled corporation, was governed by the Civil Service Law. Mercado opposed on March 12, 1986.
Labor Arbiter Vito J. Minoria ruled for Mercado, ordering his reinstatement with full back wages, payment of P10,000.00 representing his personal share of a savings account, P30,000.00 moral damages, P20,000.00 exemplary damages, P5,000.00 attorney’s fees, and P792.50 as proportionate 13th month pay. PNOC‑EDC appealed to the NLRC, which on July 3, 1987 dismissed the appeal and affirmed the Labor Arbiter’s decision.
Petitioner sought relief in the Supreme Court by a petition for certiorari to set aside the NLRC resolution of July 3, 1987, principally contending that the NLRC lacked jurisdiction over PNOC‑EDC employees (arguing Civil Service supremacy under the 1973 Constitution and related decrees) and, alternatively, that th...(Subscriber-Only)
Issues:
- Did the Labor Arbiter and the National Labor Relations Commission have jurisdiction over employment matters affecting PNOC‑EDC (a government‑owned or controlled corporation)?
- If jurisdiction exists, were the Labor Arbiter’s and NLRC’s orders reinstating Mercado and awarding savings, proportionate 13th month pay, damages and ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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