Case Summary (G.R. No. 199027)
Applicable Law
This case is governed primarily by the 1987 Philippine Constitution and the Labor Code of the Philippines, particularly Articles 128 and 217. Article 128 outlines the visitorial and enforcement powers of the Secretary of Labor and his representatives, while Article 217 delineates the original and exclusive jurisdiction of Labor Arbiters over money claims by workers.
Sequence of Events
The situation began on July 28, 1986, when Rowena Reteracion, representing the Mansion House Genuine Labor Union, filed a request for inspection of the restaurant due to alleged non-compliance with labor standards, including issues related to minimum wage and 13th month pay. An inspection ensued on July 30, 1986, leading to multiple visits where the petitioner failed to provide required employment records. By October 7, 1986, a Final Order for Compliance was issued to the petitioner, mandating the payment of P254,841.26 to the complainants based on claims of underpayment and non-payment of benefits.
Grounds for Certiorari
The petitioner filed a motion for reconsideration of the Final Order on the grounds that the Regional Director lacked jurisdiction over money claims, which should exclusively be handled by the National Labor Relations Commission. Furthermore, the petitioner claimed he was denied due process as he was not provided copies of the affidavits supporting the claims against him. The motion was denied by the public respondent, asserting that jurisdiction was appropriately assumed under Article 128 of the Labor Code.
Jurisdictional Issue
A critical issue in this case relates to whether the public respondent acted beyond his jurisdiction. The petitioner maintained that the Labor Arbiter has exclusive jurisdiction over money claims as articulated in Article 217 of the Labor Code. The Solicitor General supported the petitioner, emphasizing that under Article 128, the public respondent's powers are limited to inspection and enforcement, not adjudication of monetary claims. As established in legal precedent, only Labor Arbiters may adjudicate claims for monetary benefits resulting from employer-employee relationships.
Analysis of Due Process Claims
The petitioner’s assertion that he was denied due process was examined in light of the procedural timeline. The records indicated that the petitioner was provided opportunities to present his case, including several no
...continue readingCase Syllabus (G.R. No. 199027)
Case Background
- This case involves a special civil action for certiorari filed by Antonio Ong, Sr. against Henry M. Parel, the Regional Director of the Ministry of Labor and Employment, and several other respondents.
- The petition seeks to annul orders that compel the petitioner to pay a total of P254,841.26 representing claims by thirteen complainant workers for alleged violations of labor standards laws.
Facts of the Case
- On July 28, 1986, Rowena Reteracion, president of the Mansion House Genuine Labor Union, requested an inspection of the Mansion House Restaurant owned by the petitioner due to alleged non-compliance with labor laws.
- An initial inspection occurred on July 30, 1986, but the petitioner was unable to provide business records, claiming they were with his accountant. He was given until August 4, 1986, to present the records.
- Thirteen employees signed affidavits during the inspection, corroborating the claims against the petitioner.
- On August 4, 1986, during a follow-up visit, the petitioner again failed to provide the requested records.
- A subpoena duces tecum was issued on August 7, 1986, demanding the submission of specific employment records. The petitioner did not comply with the subpoena but instead requested clarification regarding the inspection.
- On October 7, 1986, the Regional Director issued a Final Order for Compliance, ordering the petitioner to pay P254,841.26 based on the findings of the inspections.
- Fo