Title
Zambales Base Metals, Inc. vs. Minister of Labor
Case
G.R. No. 73184-88
Decision Date
Nov 26, 1986
Employees filed complaints for unpaid wages; regional director ordered payment, but Supreme Court ruled jurisdiction lies with labor arbiter, nullifying prior orders.

Case Digest (G.R. No. 73184-88)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Thirty employees of Zambales Base Metals, Inc. filed complaints with the Office of the Regional Director, Region IX, Ministry of Labor.
    • The complaints involved claims for unpaid wages, 13th month pay, and service incentive leave pay.
  • Investigation and Admission of Non-Payments
    • The regional director required the petitioner to submit its employment records and payrolls for verification of the claims.
    • During the verification, a representative of the petitioner admitted to the non-payments charged by the employees.
  • Motion to Refer the Cases
    • The petitioner moved that the cases be referred to the labor arbiter, arguing that the regional director lacked jurisdiction.
    • The motion was not acted upon, leaving the case proceeding under the regional director’s investigation.
  • Order Issued by the Regional Director and Subsequent Proceedings
    • Based on his investigation, the regional director issued an order directing the petitioner to pay the complainants—as well as other affected workers (numbering 570 in all)—a total amount of P3,672,883.00.
    • The order was appealed to the Ministry of Labor and sustained on September 27, 1984.
    • The petitioner’s subsequent motion for reconsideration was denied on October 21, 1985.
  • Certification of Jurisdictional Issue
    • The petitioner raised the question of jurisdiction before the Court through a petition for certiorari.
    • The central fact contested was whether the regional director had the authority to decide on the money claims of the employees.

Issues:

  • Jurisdiction of the Regional Director
    • Whether the regional director had the power to decide the money claims filed by the employees.
    • Whether the regional director could exercise jurisdiction over a matter clearly reserved for the labor arbiters.
  • Interpretation of the Applicable Provisions of the Labor Code
    • The interpretation of Article 217 of the Labor Code as conferring "original and exclusive jurisdiction" on the labor arbiters for cases involving money claims.
    • The scope of the authority of the regional director under Article 128 of the Labor Code, which is limited to visitorial powers and compliance with labor standards.
  • Validity of the Proceedings and Orders
    • Whether the proceedings initiated by the regional director were valid given the alleged lack of jurisdiction.
    • The appropriateness of the orders issued by the Ministry of Labor based on the regional director’s findings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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