CENTRO ESCOLAR UNIVERSITY, PETITIONER, VS. CALIXTO WANDAGA, SEGUNDO CRUZ, FRANCIS DAO-AS, EMI­LIANO PISEW, MARIA NAVARRO, VICTOR MARTINEZ, ELPIDIO RIVERA, DANIEL ORTIGUERO, CESA…

Centro Escolar University versus Wandaga

The Case

This is a special civil action for certiorari with preliminary injunction, brought by Centro Escolar University against Calixto Wandaga and his fellow janitors and janitress, to stop the Court of Industrial Relations from proceeding with their complaint for overtime pay, refund of illegal deductions, underpayment, and reinstatement. The University insists that the industrial court has no jurisdiction over money claims founded on the Eight-Hour Labor Law and the Minimum Wage Law, and that a prior claim filed with a regional office of the Department of Labor bars the case. The decision matters because it fixes the dividing line between the jurisdiction of the Court of Industrial Relations and that of the regular courts in labor money claims, and because it settles the effect of a prior claim before a Labor regional office.

Procedural History

Eight janitors and one janitress filed a petition in the Court of Industrial Relations against Centro Escolar University for recovery of overtime compensation, illegal deduction and underpayment, with reinstatement. The University moved to dismiss on the ground of lack of jurisdiction and on the ground of pendency of another action. The Court of Industrial Relations ruled that it had jurisdiction, and that the pendency of another action did not apply because the complaint before the Department of Labor did not ask for reinstatement. The University's motion for reconsideration was denied by the Court of Industrial Relations en banc. The University then filed with the Supreme Court this special civil action for certiorari with preliminary injunction, contending that appeal in due time was not an adequate remedy, and seeking to enjoin the Court of Industrial Relations from further proceeding with the case.

Facts

The complainants were employed by Centro Escolar University as janitors and janitress, some as far back as 1962, until February 27, 1965, when the University dismissed them. They alleged that the dismissal was discriminatory, without notice and without cause. When they refused to accept their separation pay or to sign a separation agreement, the amounts were sent to them by registered mail, and they expressed willingness to return them.

They further alleged that they worked thirteen hours from Monday to Saturday, and seven hours during Sundays and holidays, without extra compensation; that illegal deductions of twelve pesos were made against three of them; that they were paid below the minimum wage fixed by law; and that the University refused to pay their claims.

Before the present case, a claim for the same amounts had been filed by the petitioners before Regional Office Number Four of the Department of Labor. The University invoked that earlier claim as a bar, while the complainants pressed their prayer for reinstatement before the Court of Industrial Relations.

Issues

• Whether or not the Court of Industrial Relations has jurisdiction over claims for overtime work under the Eight-Hour Labor Law, and for underpayment and refund of illegal deductions under the Minimum Wage Law, there being a claim for reinstatement.
• Whether or not the case should be dismissed due to the pendency of another action for the same cause before Regional Office Number Four of the Department of Labor.

Applicable Provisions

Section 10 of Republic Act 875, the Industrial Peace Act, defines one class of cases within the jurisdiction of the Court of Industrial Relations:

Labor disputes affecting an industry which is indispensable to the national interest and so certified by the President to the Court.

This provision marks the first of the jurisdictional categories the Court enumerates, and it is not the category on which the present claims rest.

Section 5 of Republic Act 875, the Industrial Peace Act, covers another category:

Cases involving unfair labor practice.

The Court lists this as the fourth category of industrial court jurisdiction, and it is significant here because the University argued that reinstatement alone, without any allegation of unfair labor practice, could not confer jurisdiction.

Republic Act 602, the Minimum Wage Law, supplies the second category of controversies:

Controversies about the minimum wage under the Minimum Wage Law.

The claim for underpayment in this case falls under this category.

Commonwealth Act 444, the Eight-Hour Labor Law, supplies the third category:

Controversies regarding hours of employment under the Eight-Hour Labor Law.

The claim for overtime compensation falls under this category.

Section 25 of Reorganization Plan Number 20-A is the provision the Court strikes down as void:

Such regional offices do not have jurisdiction over such money claims of laborers under the Minimum Wage Law and Eight-Hour Labor Law, because Reorganization Plan No. 20-A, particularly Section 25, which purported to grant it such jurisdiction, is null and void.

This holding disposes of the defense of pendency of another action, since the earlier forum had no authority over the claims.

Ruling

On the first issue, the Court held that the jurisdiction of the Court of Industrial Relations extends only to four categories of cases: labor disputes affecting an industry indispensable to the national interest and certified by the President; controversies about the minimum wage under the Minimum Wage Law; controversies regarding hours of employment under the Eight-Hour Labor Law; and cases involving unfair labor practice. For such disputes to fall within that jurisdiction, the employer-employee relationship must exist, or, if it had been terminated, the employee must seek reinstatement. When the relationship has ceased and the employee does not seek reinstatement, the claims become merely money claims falling within the jurisdiction of the regular courts. Applying this norm, the Court found that the principal claims fall under the Minimum Wage Law and the Eight-Hour Labor Law and are coupled with a prayer for reinstatement, so they fall squarely within the industrial court's jurisdiction. In line with the rule against splitting a cause of action, the other claims arising out of or incidental to the principal ones are likewise cognizable by the same court.

On the second issue, the Court held that there can be no bar due to pendency of another action, because the regional offices of the Department of Labor do not have jurisdiction over money claims of laborers under the Minimum Wage Law and the Eight-Hour Labor Law. The provision of Reorganization Plan Number 20-A that purported to grant such jurisdiction is null and void. The Department of Labor, through its regional offices, has jurisdiction only over money claims under the Workmen's Compensation Act.

Doctrine

The Court of Industrial Relations has jurisdiction over claims for overtime pay under the Eight-Hour Labor Law and for underpayment and refund of illegal deductions under the Minimum Wage Law only when the employer-employee relationship still exists, or, if it has been terminated, when the employee seeks reinstatement. Once that relationship has ceased and reinstatement is not sought, the claims are mere money claims cognizable by the regular courts. Where the principal claims fall within the industrial court's jurisdiction, incidental claims arising out of them are likewise within that jurisdiction, under the rule against splitting a cause of action. Finally, a prior claim filed before a regional office of the Department of Labor does not bar a subsequent action, because those offices have no jurisdiction over money claims under the Minimum Wage Law and the Eight-Hour Labor Law; their authority extends only to claims under the Workmen's Compensation Act.

Disposition

The petition was denied, the Court of Industrial Relations was declared to have jurisdiction over the case, and the parties were enjoined to proceed further, with costs against the University.

Remember This

The single line to memorize is this: reinstatement is the hinge of industrial court jurisdiction over labor money claims, and absent it the claim belongs to the regular courts. Examiners use this case to test jurisdiction over money claims under the labor laws and the rule against splitting a cause of action.