Case Summary (G.R. No. 58494)
Background of the Case
On January 20, 1978, PNOC-EDC filed an application with the Ministry of Labor and Employment (MOLE) for clearance to terminate Ellelina's services due to alleged criminal behavior. Initially, MOLE granted the clearance but later revoked it, mandating Ellelina's reinstatement alongside backwages. PNOC-EDC's appeal to the Minister of Labor was affirmed, leading to the filing of this Petition for Certiorari challenging the jurisdiction of MOLE and the validity of the dismissal.
Applicable Law and Jurisdictional Issues
The primary legal framework relevant to the case is rooted in the Labor Code and the Civil Service Law. PNOC-EDC contends that it is a government-owned corporation not under the jurisdiction of the Labor Code, as articulated in Article 277 of the Labor Code, which specifies that employees of such entities are governed by the Civil Service Law. The petitioner argues that the jurisdiction of the Ministry of Labor does not extend to it, as it is a government-owned or controlled corporation created under the general Corporation Law.
Respondent's Position
In contrast, the public respondent argues that PNOC-EDC is indeed subject to the Labor Code because it, as a subsidiary, was organized under the Corporation Law and registered with the Securities and Exchange Commission. The public respondent also argues that the petitioner's argument of jurisdiction is negated by the principle of estoppel, as PNOC-EDC engaged with the Labor Department by applying for the clearance.
Supreme Court's Analysis of Jurisdiction
The Supreme Court reviewed the applicability of the 1973 Constitution, which previously governed such distinctions, and confirmed that under the current framework provided by the 1987 Constitution, the distinction between government corporations created by special charter versus those under the general Corporation Law would determine their coverage by the Civil Service Law. The Court reaffirmed the principle established in the case of National Housing Corporation vs. Juco, recognizing that government corporations formed under the general Corporation Law fall under the Labor Code's provisions.
Conclusion on Reinstatement and Backwages
Addressing Ellelina’s case, the Court upheld the order for reinstatement due to the nature of the offense committed being relativ
...continue readingCase Syllabus (G.R. No. 58494)
Introduction
- This case concerns a Petition for Certiorari filed by the Philippine National Oil Company-Energy Development Corporation (PNOC-EDC) against Hon. Vicente T. Leogardo, the Deputy Minister of Labor, and Vicente D. Ellelina.
- The petitioner seeks to declare void the Deputy Minister's Order, asserting a lack of jurisdiction over the case regarding Ellelina's termination.
Background of the Case
- PNOC-EDC, a subsidiary of the Philippine National Oil Company, filed for clearance to terminate Vicente D. Ellelina, a contractual employee, on January 20, 1978.
- The basis for termination was an incident that occurred at a Christmas party on December 19, 1977, where Ellelina allegedly attempted to seize a firearm after disputing a prize.
- Initially, the Ministry of Labor and Employment (MOLE) granted the clearance but later revoked it, ordering Ellelina's reinstatement with backwages.
Legal Issues Raised
- The petition raised two primary issues:
- Whether the Deputy Minister of Labor committed grave abuse of discretion in asserting jurisdiction over the case involving PNOC-EDC.
- Whether Ellelina's dismissal was justified based on the circumstances presented.
Jurisdictional Considerations
- PNOC-EDC contended that, under Article 277 of the Labor Code, it was not subject to the jurisdiction of the Mini