Case Summary (G.R. No. 165003)
Procedural History
On October 24, 1975, Bengzon filed a complaint for illegal dismissal against Sta. Ines and Hyde with the Regional Office No. IV of the Department of Labor. The Labor Arbiter rendered an initial decision on March 31, 1976, ordering Sta. Ines to pay Bengzon ₱2,500 for separation pay and Hyde to pay ₱300,000 for moral and exemplary damages. Subsequently, both parties filed appeals on various grounds.
NLRC and Subsequent Developments
The National Labor Relations Commission (NLRC) remanded the case to the Labor Arbiter on June 1, 1976, primarily due to jurisdiction issues concerning Hyde. After further proceedings, an amended complaint was filed, resulting in a consolidated decision by the Labor Arbiter on November 18, 1977, which ordered both respondents to jointly and severally pay total damages.
NLRC Decision and Presidential Decree No. 1367
The NLRC issued a modified decision on February 21, 1978, which awarded backwages and altered the previous damage awards. On May 1, 1978, Presidential Decree No. 1367 was enacted, amending Article 217 of the Labor Code and effectively removing the jurisdiction of Labor Arbiters over claims for moral damages. Following this, the Deputy Minister of Labor issued an order on July 17, 1978, upholding the NLRC's decision but nullifying the damage awards based on the new jurisdictional limits set by the decree.
Legal Arguments
Bengzon argued that the Deputy Minister improperly disclaimed jurisdiction over the damage claims, asserting that under the pre-amendment Labor Code, Labor Arbiters had jurisdiction over such claims. Conversely, Sta. Ines argued that the moral damage claims were cognizable only in regular courts and that the amendment aimed to restrict the Labor Arbiters' jurisdiction.
Jurisdictional Authority Before the Decree
The principal issue concerns whether the Labor Arbiter had the authority to award moral and exemplary damages prior to the enacting of the Presidential Decree. Article 217 of the Labor Code, as it stood before its amendment, clearly delineated the jurisdiction of Labor Arbiters over cases involving employer-employee relations, which extended to claims for moral damages.
Court's Conclusion on Jurisdiction
The Supreme Court concluded that any statute altering jurisdiction should not retroactively affect cases that were already within the jurisdiction of a court or administrative body prior to the enactment of such statutes. Given that the complaints for damages were initiated before the Presidential Decree e
...continue readingCase Syllabus (G.R. No. 165003)
Case Overview
- The case involves a petition for certiorari by Lourdes E. Bengzon against the Deputy Minister of Labor and Sta. Ines-Melale Veneer & Plywood Corporation, challenging an Order dated July 17, 1978.
- The petition seeks to reverse the prior decisions regarding claims of illegal dismissal, backwages, and damages.
Background of the Case
- On October 24, 1975, the petitioner filed a complaint for illegal dismissal against Sta. Ines and its Vice-President, Robert V. Hyde.
- The Labor Arbiter issued a decision on March 31, 1976, ordering Sta. Ines to pay Bengzon P2,500.00 as separation pay and Hyde P300,000.00 as moral and exemplary damages.
- Bengzon appealed, seeking to hold Sta. Ines solidarily liable for damages, while Hyde contested the jurisdiction over him, claiming improper summons.
Proceedings and Decisions
- On June 1, 1976, the National Labor Relations Commission (NLRC) remanded the case back to the Labor Arbiter due to lack of jurisdiction over Hyde.
- Subsequent to further hearings, on November 18, 1977, the Labor Arbiter ruled that both Sta. Ines and Hyde should pay Bengzon P2,500.00 and P300,000.00, respectively.
- The NLRC modified this decision on February 21, 1978, awarding Bengzon P54,394.62 for backwages, P2,000.00 as separation pay, and