Case Summary (G.R. No. L-47629)
Background of the Case
The case originates from a decision dated August 3, 1978, wherein it was determined that the Court of First Instance, Davao City Branch VI, lacked the jurisdiction to address Velasco's complaint for damages, citing that such matters should be adjudicated by the National Labor Relations Commission (NLRC). The decision was based on Article 217 of the Labor Code, which confers jurisdiction to Labor Arbiters for claims arising from unlawful dismissal, including damage awards.
Amendment to Jurisdiction
Velasco filed a second motion for reconsideration, invoking Presidential Decree No. 1367, effective May 1, 1978. This decree amended Section 217(a) of the Labor Code, restricting Labor Arbiters from entertaining claims for moral or other kinds of damages unless specified conditions are met. This amendment’s textual modification specified that while Labor Arbiters maintain exclusive jurisdiction over various labor-related disputes, they would not deal with moral or other damages.
Legal Analysis of Jurisdiction
The court analyzed the effect of the amendment and concluded that, upon the amendment's enactment, the previously existing lack of jurisdiction that affected Velasco's complaint was effectively rectified. The amendatory decree functioned as a curative statute with a retrospective application, thus legitimizing the jurisdiction of the lower court over pending cases, including Civil Case No. 9657.
Ruling and Conclusion
Ultimately, the decision that previously set aside jurisdiction was overturned. The court dismissed the petition for reconsideration, thus allowing the lower court to proceed with further proceedings for the dispo
...continue readingCase Syllabus (G.R. No. L-47629)
Case Overview
- This case involves the petition for reconsideration filed by Jose Velasco, Jr. against the decision dated August 3, 1978, which determined that the Court of First Instance, Davao City Branch VI, lacked jurisdiction over his complaint.
- The complaint sought actual and moral damages totaling P167,000, stemming from Velasco's dismissal as manager of a radio station.
Jurisdictional Issues
- The original ruling indicated that Velasco's complaint should have been filed with the National Labor Relations Commission (NLRC), as outlined in Article 217 of the Labor Code.
- Article 217 grants Labor Arbiters jurisdiction over claims for damages resulting from unjustified employee dismissals.
- Velasco's second motion for reconsideration is based on the amendments made by Presidential Decree No. 1367, effective May 1, 1978.
Amendment Under Presidential Decree No. 1367
- The amendment to Section 217(a) of the Labor Code states that Regional Directors of the Ministry of Labor