OLIVO G. RUIZ, PETITIONER AND APPELLANT, VS. CEDAR V. PASTOR RESPONDENT AND APPELLEE.

Ruiz versus Pastor

The Case

This is the case of Ruiz versus Pastor, decided by the Supreme Court in April 1962. Olivo Ruiz, the president of a stevedoring company, was held liable by a regional hearing officer of the Department of Labor for unpaid shares and wages of twenty-six laborers. Ruiz went to the Court of First Instance of Cebu to challenge the authority of that regional office to decide the claim at all. The case matters because it fixes a constitutional boundary: an executive reorganization plan cannot transfer to administrative offices the judicial power that belongs to courts of justice, and any such grant is null and void.

Procedural History

Vicente Carin and twenty-five others filed a complaint with the Regional Office of the Department of Labor in Cebu City for the recovery of shares and back wages. After hearings, Cedar Pastor, the regional hearing officer, rendered judgment ordering Ruiz to pay the claimants. Ruiz moved for reconsideration, and the motion was denied.

Ruiz then filed with the Court of First Instance of Cebu a petition for certiorari and prohibition with preliminary injunction, assailing the validity of Section 25 of Reorganization Plan No. 20-A, which gave regional offices original and exclusive jurisdiction over labor standards claims. The injunction was issued, but after the parties submitted a stipulation of facts, the trial court upheld the constitutionality of the plan and denied the writ for lack of merit.

Ruiz appealed that judgment to the Supreme Court, which resolved the appeal on the sole issue of the validity of Section 25 of the plan.

Facts

On May 27, 1957, Vicente Carin and twenty-five others filed a complaint with the Regional Office of the Department of Labor in Cebu City against the Agusan Mindanao Timber Corporation, the Nasipit Lumber Company, Olivo Ruiz as president of the Nasipit Stevedoring Corporation, and officers of the Nasipit Labor Union. They sought recovery of shares and back wages amounting to 23,781 pesos.

After conducting hearings, Cedar Pastor of the Regional Office rendered judgment on February 24, 1958, adjudging Ruiz, as president of the Nasipit Stevedoring Company, to pay the claimants the total amount of 23,781 pesos, representing unpaid shares and salaries due them from January 7 to May 21, 1957.

Ruiz moved for reconsideration, which was denied. He then brought the matter to the Court of First Instance of Cebu, questioning whether the regional office had any power to adjudicate the claim in the first place.

Issues

• Whether or not Section 25 of Reorganization Plan No. 20-A, granting regional offices original and exclusive jurisdiction over claims of laborers arising from violations of labor standards, is valid.
• Whether or not the regional hearing officer had jurisdiction to render the judgment ordering Ruiz to pay the claimants.

Applicable Provisions

Section 25 of Reorganization Plan No. 20-A, as described in the decision, granted the regional offices original and exclusive jurisdiction over labor standards claims. The Court's ruling turns on the limits of Republic Act No. 997, the reorganization statute, as construed in its prior decisions:

So that it was not the intention of Congress, in enacting Rep. Act No. 997, to authorize the transfer of powers and jurisdiction granted to courts of justice from those, to the officials to be appointed or offices to be created by the Reorganization Plan.

This passage bears directly on the case because it denies the Reorganization Commission any authority to move judicial power to an executive office.

Ruling

On the first issue, the Court held that Section 25 of Reorganization Plan No. 20-A is null and void. It relied on its earlier ruling in Cagalawan versus Customs Canteen, where it declared that the Legislature could not have intended to grant such powers to the Reorganization Commission, an executive body, because the Legislature may not and cannot delegate its power to legislate or to create courts of justice to any other agency of the Government. The Court quoted its prior holding:

The Legislature could not have intended to grant such powers to the Reorganization Commission, an executive body, as the Legislature may not and cannot delegate its powers to legislate or create courts of justice to any other agency of the Government.

And it concluded:

the provision of Reorganization Plan No. SO-A, particularly See. 25, which grants to the regional offices original and exclusive jurisdiction over money claims of laborers, is null and void, said grant having been made without authority by Rep. Act No. 997

On the second issue, it follows that the regional hearing officer had no jurisdiction to adjudicate the claim and to order Ruiz to pay. The Court found the cited authorities definitive and saw no reason to elaborate further.

Doctrine

An executive reorganization plan cannot confer on regional or administrative offices the judicial power to adjudicate money claims, because that power belongs to courts of justice. The Legislature may not delegate its power to legislate or to create courts of justice to any other agency of the Government, and a grant of original and exclusive jurisdiction to regional offices over laborers' money claims, made under Republic Act No. 997, is null and void for having been made without authority. A judgment rendered by such an office is therefore without jurisdiction, and the claim must be ventilated with the proper court.

Disposition

The Supreme Court set aside the decision appealed from and entered another dismissing the case, not the appeal, without prejudice to its ventilation with the proper court, with no costs. Ruiz won.

Remember This

Memorize the line that an executive reorganization plan cannot transfer judicial power to administrative offices, so Section 25 of Reorganization Plan No. 20-A is null and void. Examiners use this case on the non-delegation of judicial power and on the jurisdiction of labor regional offices over money claims.