Case Digest (G.R. No. 85840)
Facts:
SERVANDOS INCORPORATED, PETITIONER, sought relief from orders of THE SECRETARY OF LABOR AND EMPLOYMENT and THE REGIONAL DIRECTOR, REGION VI, DEPARTMENT OF LABOR AND EMPLOYMENT, RESPONDENTS, following a DOLE inspection that found labor standards violations and led the Regional Director to order payment to fifty-four employees totaling P964,952.50, with each employee's award exceeding P5,000.00. The Regional Director's orders were affirmed by the NLRC; on April 26, 1990 the Court ordered referral of the contested money claims to the Labor Arbiter, and the Respondents filed a motion for reconsideration.
Issues:
- Does the visitorial and enforcement power under Article 128(b) permit the Secretary or his representatives to hear and decide employee money claims exceeding P5,000.00 per employee?
- When the employer contests the findings of labor regulation officers and raises evidentiary issues not verifiable in inspection, must the matter be referred to the Labor Arbiter despite Article 128(b)?
Ruling:
The Court denied the respondents' motion for reconsideration and reaffirmed its April 26, 1990 disposition. The Court held that money claims arising from employer-employee relations exceeding P5,000.00 per employee fall within the exclusive original jurisdiction of the Labor Arbiter, and findings under Article 128(b) that disclose such claims must be referred to the Labor Arbiter when contested or involving evidentiary matters not verifiable in inspection.
Ratio:
The Court harmonized Article 217 (a)(6), Article 129, and Article 128(b) by construing Article 128(b)'s visitorial and enforcement powers as plenary for inspections and summary enforcement but limited where employer contests the inspectors' findings or where resolution requires evidentiary proceedings not verifiable in the normal course of inspection. To read Article 128(b) as empowering summary adjudication of contested claims exceeding P5,000.00 would nullify the exclusive jurisdiction conferred by Article 217 and the limitation in Article 129 and would defeat due process where substantial monetary awards are involved.
Doctrine:
- Article 217 (a)(6) vests exclusive original jurisdiction in the Labor Arbiter over money claims arising from employer-employee relations exceeding P5,000.00 per employee.
- Article 129 limits the Regional Director's summary adjudicatory authority to simple money claims not exceeding P5,000.00 per employee and excluding reinstatement claims.
- Article 128(b) grants the Secretary and his representatives visitorial and enforcement powers to inspect, order compliance, and issue writs of execution, but not to adjudicate contested claims requiring evidentiary determinations not verifiable in inspection.
- When inspection findings disclose contested monetary claims exceeding P5,000.00 per employee, the proper procedure is referral to the Labor Arbiter for formal adjudication.