Title
Victoria Biscuit Co., Inc. vs. Benedicto
Case
G.R. No. L-18800
Decision Date
Mar 30, 1963
A labor dispute over overtime pay led to jurisdictional challenges, with the Supreme Court ruling the Labor Standards Commission lacked authority, nullifying its decision.

Case Summary (G.R. No. L-18800)

Procedural History

Dionisio Bania filed a complaint against Victoria Biscuit Co., Inc. with the Regional Office No. 3 of the Department of Labor seeking recovery of overtime and separation pay. The Regional Office initially dismissed the complaint for lack of merit, prompting Bania to appeal to the Labor Standards Commission, which reversed the initial dismissal regarding overtime, awarding Bania P1,901.74 including legal interest.

Review and Subsequent Proceedings

Victoria Biscuit Co. sought to contest the Commission's decision, and upon appeal, the Commission modified the initial award, reducing it to P904.87. Rather than respond to the appeal during the subsequent Civil Case No. 43863, Victoria Biscuit Co. filed a motion for dismissal based on jurisdictional grounds, the assertion of prescription, and a claimed release of the demand. Bania concurred with the motion for dismissal, although not necessarily with all its grounds.

Dismissal by the Court of First Instance

The Court of First Instance of Manila, under Judge Conrado M. Vasquez, granted the motion, leading to the dismissal of Civil Case No. 43863. Despite this, the Labor Standards Commission later issued a writ of execution to enforce its decision, culminating in Victoria Biscuit Co.'s petition for certiorari and prohibition against the execution.

Arguments and Decision of the Higher Court

Victoria Biscuit Co. contended that the dismissal of Civil Case No. 43863 impliedly nullified the Labor Standards Commission's decision. Conversely, Bania argued that his conformity to the dismissal acted as a revival of the Commission's judgment. However, the court determined that the dismissal was based on jurisdictional issues.

Court's Ruling on Jurisdiction

The court reiterated its prior rulings asserting that the Regional Office No. 3 and the Labor Stand

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.