G.R. No. 87449 - South Motorists Enterprises vs. Tosoc

This is a special civil action for certiorari questioning the jurisdiction of the Regional Directors of the Department of Labor and Employment (DOLE) to hear and decide monetary claims arising from employer-employee relationships.
Petitioner South Motorists Enterprises (SOUTH MOTORISTS) challenged the decision that awarded emergency cost of living allowances to its employees, asserting that such cases fall under the exclusive jurisdiction of the Labor Arbiters.

In January 1983, 46 workers (complainants such as Tosoc, et al.) filed complaints for non-payment of emergency cost of living allowances against SOUTH MOTORISTS before the Naga City District Office of Regional Office No. 5 of the then Ministry of Labor.
On 10 January 1983, a Special Order was issued directing Labor Regulation Officers to inspect and verify SOUTH MOTORISTS’ employment records.
During the inspection, SOUTH MOTORISTS was unable to produce its employment records, claiming they had been sent to its main office in Manila.

The case was first set for a conference on 25 January 1983, then reset to 8 February 1983 at the company's request for additional time to present the employment records.
SOUTH MOTORISTS requested another deferment on 7 February 1983, moving the hearing to 16 February 1983, citing the tight schedule of its lawyer.
Further, on 16 February 1983, the petitioner requested a resetting to 3 March 1983 due to the voluminous nature of the records and the need to submit a memorandum regarding the employees’ claims.
On 2 March 1983, another 30-day extension was requested by SOUTH MOTORISTS to allow for the preparation and collation of documents, which was not followed up with any formal manifest or motion.

On 7 March 1983, the Labor Regulation Officers submitted an Inspection Report.
Based on this report, an Order was issued on 14 April 1983 by Labor Officer Domingo Reyes directing SOUTH MOTORISTS to pay an aggregate of P184,689.12 as emergency cost of living allowances to the 46 employees.
SOUTH MOTORISTS moved for reconsideration of the Order, which was denied; this denial was later affirmed by the Secretary of Labor and Employment on 11 July 1988, and subsequent motions for reconsideration (filed on 28 July 1988 and 7 March 1989) were also unsuccessful.

The detailed award itemized each of the 46 individual monetary claims, several of which exceeded the threshold of P5,000.00.
Two key provisions were at issue:

Article 129 of the Labor Code (as amended by R.A. 6715) which allows Regional Directors to conduct summary proceedings for money claims up to P5,000, provided the claim is strictly monetary and there is no issue of reinstatement.
Article 217 of the Labor Code, which vests original and exclusive jurisdiction in Labor Arbiters for claims exceeding P5,000 arising from employer-employee relations.

The retroactive application of the amendments under R.A. 6715 (as in the Briad Agro and Camus Engineering cases) played a significant role in interpreting the jurisdiction of the labor authorities.

SOUTH MOTORISTS repeatedly failed to present its employment records and cause delays by requesting multiple resets of hearings.
The petitioner’s repeated postponements and absence of submitted evidence were contrasted with its responsibility to maintain and produce employment records as mandated by Section 11 of Rule X, Book II of the Omnibus Rules Implementing the Labor Code.
These lapses were considered by the court as a waiver of its right to contest the claim and adduce evidence contrary to the workers’ allegations.

Does the Regional Director have the authority to decide on money claims in cases like these, particularly when the award exceeds the limit of P5,000 as set by the amended Article 129 of the Labor Code?
Is the award rendered by the Regional Director valid when some claims should exclusively fall under the jurisdiction of the Labor Arbiters pursuant to Article 217 of the Labor Code?

To what extent do SOUTH MOTORISTS’ repeated requests for postponements and failure to provide employment records affect its ability to contest the claims?
Does the repeated non-compliance in presenting employment records, in violation of the applicable rules, result in a waiver of its right to adduce evidence against the claims of the workers?

How do the retroactively effective amendments brought by R.A. 6715 to Articles 129 and 217 influence the jurisdiction over claims, especially considering the timing of the proceedings?