G.R. No. L-18453 - Campos Rueda Corporation vs. Bautista

The Court of Industrial Relations lacks jurisdiction over claims for overtime pay when the complainant does not seek reinstatement.
In this case, the complainant, Manuel Muyot, filed a complaint nearly five years after his employment was terminated, solely seeking compensation for overtime, Sunday, and holiday work.
The absence of a request for reinstatement indicates that the case does not fall under the jurisdiction of the Court of Industrial Relations.

The jurisdiction of a court is determined by the allegations in the complaint or petition.
This principle is applicable to the Court of Industrial Relations, as established in previous rulings.
The nature of the claims made in the complaint dictates the court's jurisdiction.

A complaint cannot be amended to confer jurisdiction on a court if the original cause of action was outside the court's jurisdiction.
This principle was reiterated in prior cases, emphasizing that jurisdiction cannot be established through amendments if it was not present initially.

Manuel Muyot was employed by Campos Rueda Corporation from May 21, 1949, to December 31, 1953, with a monthly salary that increased during his employment.
He filed a complaint on November 26, 1958, seeking compensation for unpaid overtime and holiday work.
The petitioner moved to dismiss the complaint, citing various grounds, including the statute of limitations and previous decisions from other courts.

Muyot opposed the motion to dismiss, arguing that previous decisions did not constitute res judicata due to lack of jurisdiction and that his claims were not barred by the statute of limitations.
He contended that the legal period for filing was interrupted by his earlier cases with the Department of Labor and the Court of First Instance.

The Court of Industrial Relations denied the motion to dismiss and required the petitioner to respond to the complaint.
The court also denied a motion to quash a subpoena for daily time records, which the petitioner argued was overly broad and irrelevant.

Campos Rueda Corporation filed a petition for certiorari and prohibition to annul the orders of the Court of Industrial Relations.
The allegations in Muyot's complaint confirmed that he was no longer employed and did not seek reinstatement, reinforcing the lack of jurisdiction.

Previous cases established that claims for unpaid wages after termination, without a request for reinstatement, do not fall under the jurisdiction of the Court of Industrial Relations.
The court reiterated that once the employer-employee relationship is terminated and no reinstatement is sought, claims become mere money claims, falling under the jurisdiction...continue reading