Case Summary (G.R. No. 106231)
Relevant Dates
The petition was handled under RAB VI Case No. 06-07-10256-89, initiated on July 4, 1989. The Labor Arbiter's order, which the petitioner is challenging, was issued on June 29, 1992, with the appeal filed thereafter.
Applicable Law
The decision primarily cites the 1987 Philippine Constitution, as the resolution was rendered following 1990, alongside references to pertinent provisions from the Labor Code and Republic Act 809, also known as the Sugar Act of 1952.
Background of the Case
The NFSW-FGT filed complaints against the Hawaiian-Philippine Company for failing to provide benefits under the Sugar Act of 1952. Specifically, the complaint alleged that sugar farm workers in the milling district had not received mandated benefits. The Act’s provisions state that benefits accrued from increased participation in profits must be divided between laborers and planters, with laborers receiving a sixty percent share.
Petitioner’s Position
The petitioner filed multiple motions to dismiss, arguing that the Labor Arbiter lacked jurisdiction over the case and that there was no employer-employee relationship between them and the sugar workers represented in the complaint. They referred to Article 217 of the Labor Code, which delineates the Labor Arbiter's jurisdiction only over cases arising from employer-employee relations. The petitioner contended that their role as a milling company does not create such an obligation to the farm workers.
Jurisdictional Issues
Petitioner referenced precedents, including San Miguel Corporation v. NLRC, asserting that all disputes under the jurisdiction of Labor Arbiters must arise from an employer-employee relationship. In this case, it was argued that no such relationship existed between the milling company and the farm workers. Petitioner reiterated that its obligation was purely to distribute the planters' shares rather than directly to the laborers.
Opposition from Public Respondent
Conversely, the public respondent maintained that there might still be a liability on the part of the petitioner because it did not ensure that all workers received their lawful shares. The Labor Arbiter suggested that the absence of confirmation regarding payments to workers indicated a potential liability, necessitating the inclusion of the petitioner in the proceedings as an indispensable party.
Legal Analysis and Findings
In its analysis, the court underscored the lack of jurisdiction on the part of the Labor Arbiter due to the absence of an employer-employee relationship between the petitioner and the workers. The court emphasized that, according to the law, it is the responsibility of the planters—not the milling company—to directly pay laborers their rightful shares. It reiterated that disputes must arise out of employer-employee relations to fall under the jurisdiction of the Labor Arbiter, as per Article 217.
Conclusion
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Case Overview
- This case involves a petition for certiorari and prohibition with preliminary injunction filed by Hawaiian-Philippine Company against Reynaldo J. Gulmatico, a Labor Arbiter, and the National Federation of Sugar Workers-Food and General Trades (NFSW-FGT).
- The petition seeks to annul the Order issued on June 29, 1992, which denied the company's motion to dismiss a complaint filed by the respondent union claiming benefits under Republic Act No. 809 (The Sugar Act of 1952).
Procedural History
- On July 4, 1989, NFSW-FGT filed RAB VI Case No. 06-07-10256-89 against Hawaiian-Philippine Company for claims under the Sugar Act, alleging that sugar farm workers had not received benefits due to them.
- Hawaiian-Philippine filed a Motion to Dismiss on July 31, 1989, arguing lack of jurisdiction and absence of cause of action, which was opposed by the union.
- The Labor Arbiter denied the motions to dismiss on June 29, 1992, leading to the petition by Hawaiian-Philippine.
Key Legislative Provisions
- Republic Act No. 809, Section 9: Establishes the distribution of benefits from increased participation in the sugar industry, mandating 60% to laborers and 40% to planters, with the Department of Labor supervising the distribution.
- Article 217 of the Labor Code: Outlines the jurisdiction of Labor Arbiters over cases involving employer-employee relationships, including unfair labor practices, termination disputes, and claims related to wages and work conditions.