Case Summary (G.R. No. 73184-88)
Complaints and Initial Proceedings
The regional director mandated the petitioner to provide employment records and payrolls for verification. During this process, a representative of the petitioner acknowledged the validity of the non-payment claims made by the employees. In response, the petitioner contended that the regional director lacked jurisdiction over the case and requested that the complaints be forwarded to a labor arbiter. However, this motion went unaddressed.
Regional Director's Order
Subsequent to the investigation, the regional director issued an order directing Zambales Base Metals, Inc. to compensate the complainants and additional affected workers, totaling approximately P3,672,883.00. This order was later upheld upon appeal to the Ministry of Labor on September 27, 1984, and a subsequent motion for reconsideration filed by the petitioner was denied on October 21, 1985.
Legal Issue
The primary issue under review before the court is the jurisdictional question raised by the petitioner. The legal principle guiding this case is rooted in Article 217 of the Labor Code, which delineates the original and exclusive jurisdiction of labor arbiters over various employment-related disputes, including money claims arising from wage issues.
Jurisdictional Authority
According to Article 217, labor arbiters hold exclusive jurisdiction to adjudicate complaints involving money claims of workers, such as unpaid wages and benefits. In contrast, the role of regional directors is limited to visitorial powers and does not include jurisdiction over money claims. The ruling clarifies that the regional director’s authority, as per Article 128 of the Labor Code, does not extend to the adjudicative powers possessed exclusively by labor arbiters.
Conclusion and Directive
Given that the proceedings overseen by the regional director lacked jurisdic
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Case Overview
- Court: Supreme Court of the Philippines
- Division: First Division
- G.R. No.: L-73184-88
- Date of Decision: November 26, 1986
- Petitioner: Zambales Base Metals, Inc.
- Respondents: The Minister of Labor, Deputy Minister of Labor, Regional Director David Kong, Rosalio Bangayan, et al.
Background of the Case
- Thirty employees of Zambales Base Metals, Inc. lodged complaints with the Office of the Regional Director, Region IX, Ministry of Labor.
- The complaints pertained to unpaid wages, 13th month pay, and service incentive leave pay.
- In response, the regional director mandated the petitioner to submit employment records and payrolls for verification.
- During this verification process, a representative of the petitioner conceded to the non-payment claims made by the employees.
Jurisdictional Dispute
- The petitioner contested the jurisdiction of the regional director over the complaints, arguing for referral to a labor arbiter.
- Despite the petitioner's motion, the regional director did not act on it.
- Subsequently, the regional director issued an order requiring the petitioner to pay the complainants and other affected workers a total amount of P3,672,883.00.
Appeal and Subsequent Developments
- The petitioner appealed the regional director's order to the Ministry of Labor, which upheld the order on September 27, 1984.
- A motion fo