Title
PNOC-Exploration Corp. vs. National Labor Relations Commission
Case
G.R. No. 71711
Decision Date
Aug 18, 1988
The Supreme Court ruled in favor of PNOC-EC, stating that matters of employment affecting the company are not within the jurisdiction of the Ministry of Labor and Employment, and upheld the termination of Oscar Salvador's employment as it was for a specific project.
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Case Digest (G.R. No. 71711)

Facts:

  • Complaint for illegal dismissal filed by Oscar Salvador against petitioner, PNOC-EC.
  • Complaint initially heard by Labor Arbiter Felipe T. Garduque.
  • Labor Arbiter ruled in favor of Salvador and ordered his reinstatement with full backwages and other benefits.
  • Decision affirmed by the NLRC.
  • PNOC-EC filed a petition to annul the NLRC's decision.
  • Petitioner argued that matters of employment affecting PNOC-EC are not within the jurisdiction of the Ministry of Labor and Employment.
  • Solicitor General supported this argument, stating that PNOC-EC is governed by the Civil Service Law.
  • Petitioner contended that Salvador's employment was terminated upon the completion of a specific project.

Issue:

  • (Unlock)

Ruling:

  • Supreme Court ruled in favor of the petitioner, PNOC-EC, and dismissed Salvador's co...(Unlock)

Ratio:

  1. The Court held that PNOC-EC, as a subsidiary affiliate of PNOC, is governed by the Civil Service Law and is beyond the jurisdiction of the Ministry of Labor or any of its agencies.
  • Ruling consistent with previous cases such as National Housing Authority vs. Juco, Metropolitan Waterworks and Sewerage System vs. Hernandez, and Quimpo vs. Sandiganbayan.
  • Court ruled that PNOC subsidiaries, regardless of their original status as government-owned or controlled corporations, are subject to the Civil Service Law.
  1. The Court found that Salvador's employment with PNOC-EC was for a specifi...continue reading

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