Title
Sagmit vs. Sibulo
Case
G.R. No. 64694
Decision Date
Nov 21, 1984
Employees filed unpaid wage claims; employer settled but defaulted. Regional Director ordered payment; employer challenged jurisdiction. Supreme Court ruled labor claims fall under Labor Arbiter/NLRC, voiding RTC's injunction.
A

Case Summary (G.R. No. 201821)

Factual Background

On September 14, 1981, two employees of Isabelo Asaytuno filed a complaint for recovery of unpaid wages with the Regional Office No. V of the Ministry of Labor and Employment. A third employee lodged a similar complaint on October 12, 1981. During a conciliation conference on October 14, 1981, an agreement was reached where Asaytuno was to pay the due wages in installments. However, after Asaytuno made only one payment, he ceased further payments. Consequently, on November 4, 1981, the employees filed another complaint to recover the unpaid balance.

Jurisdictional Challenge

On February 5, 1982, Director Eugenio Sagmit issued an order for Asaytuno to pay the remaining wages. Instead of complying, Asaytuno filed Civil Case No. 6801 with the Regional Trial Court seeking to prohibit Sagmit's order by claiming lack of jurisdiction as per Batas Pambansa Bilang 130 and Presidential Decree No. 1691, which he argued divested Sagmit of quasi-judicial functions.

Proceedings in Regional Trial Court

Director Sagmit moved to dismiss Civil Case No. 6801, arguing that the issues were within the exclusive jurisdiction of the Ministry of Labor and Employment, not the courts. However, on May 30, 1983, the respondent judge denied the motion, asserting that jurisdiction lies with the courts to interpret and declare rights under the law. The judge later issued a preliminary injunction on July 18, 1983, restraining Sagmit from enforcing his order.

Legal Principles and Interpretation

The core legal issue raised by Sagmit's petition revolves around whether the Regional Trial Court had jurisdiction over the matter concerning enforcement of the labor order. The Supreme Court affirmed that by virtue of PD 1691 and existing provisions in the Labor Code, the exclusive jurisdiction over money claims arising from employer-employee relationships had reverted to Labor Arbiters and the National Labor Relations Commission. The relevant provisions emphasized that the power of Regional Directors was not entirely stripped but specific

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