LUCIA PITOGO, PLAINTIFF AND APPELLANT, VS. SEN BEE TRADING COMPANY, MACARIO TAN AND SERGIO TAN, DEFENDANTS AND APPELLEES.

Pitogo versus Sen Bee Trading Company

The Case

This is an appeal by Lucia Pitogo, a seamstress, against the order of the Court of First Instance of Cebu dismissing her complaint against Sen Bee Trading Company, Macario Tan, and Sergio Tan. She sued to recover wage differentials, overtime pay, vacation and sick leave pay, moral and exemplary damages of 50,000 pesos, and other relief, all arising from her employment with the company from June 1952 to January 1958. The case matters because it tests whether an executive reorganization plan may strip the regular courts of the jurisdiction that the law itself conferred on them, and it stands as one of the series of rulings that struck down the labor jurisdiction provisions of Reorganization Plan 20-A.

Procedural History

Pitogo filed her complaint in the Court of First Instance of Cebu. The defendants moved to dismiss, contending that under Section 25, Article V of Reorganization Plan 20-A, jurisdiction over money claims of employees arising from violations of labor standards belonged to the Regional Office of the Department of Labor, not to the Court of First Instance. The trial court sustained the motion and, in an order dated June 17, 1958, dismissed the complaint. Pitogo appealed directly to the Supreme Court, squarely raising the constitutionality of Reorganization Plan 20-A on the ground that Congress may not validly delegate to a commission the power to pass laws, especially one that divests the ordinary courts of jurisdiction conferred by law.

Facts

Lucia Pitogo was employed as a seamstress by Sen Bee Trading Company from June 5, 1952 to January 11, 1958. During that period, according to her complaint, various money claims accrued in her favor: wage differentials, overtime pay, and vacation and sick leave pay, in specified amounts.

Despite demands, the defendants refused to pay her these sums. She therefore brought suit in the Court of First Instance of Cebu for recovery of the amounts, plus moral and exemplary damages of 50,000 pesos and other relief.

Instead of answering, the defendants moved to dismiss on the theory that the Regional Office of the Department of Labor, and not the Court of First Instance, had jurisdiction over money claims of employees arising from violations of labor standards under Reorganization Plan 20-A. The trial court agreed and dismissed the complaint, prompting the appeal.

Issues

• Whether or not Section 25, Article V of Reorganization Plan 20-A, which grants regional offices original and exclusive jurisdiction over money claims of laborers, is a valid exercise of legislative power.
• Whether or not Congress may validly delegate to a reorganization commission the power to create courts of justice or to divest the ordinary courts of jurisdiction conferred by law.
• Whether or not the trial court erred in dismissing the complaint for lack of jurisdiction.

Applicable Provisions

Section 25, Article V of Reorganization Plan 20-A, as described in the decision, provides the grant of jurisdiction that the Court struck down:

The provision of Reorganization Plan No. 20-A, particularly Section 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 Republic Act No. 997.

This is the very grant on which the trial court based its dismissal, and its invalidity removes the sole ground for refusing to hear Pitogo's complaint.

Republic Act No. 997, the Reorganization Act, is the source of the authority invoked, and the Court construed its scope:

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

Because the statute did not authorize the transfer, the plan's grant of jurisdiction to the regional offices had no legislative basis.

The Court also stated the constitutional limit on delegation:

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.

This fixes the constitutional ceiling: the power to create courts and to confer or withdraw their jurisdiction belongs to the Legislature alone.

Ruling

On the first issue, the Court held that Section 25, Article V of Reorganization Plan 20-A is null and void. The grant of original and exclusive jurisdiction over money claims of laborers to the regional offices was made without authority by Republic Act No. 997.

On the second issue, the Court held that Congress may not and cannot delegate to the Reorganization Commission, an executive body, its powers to legislate or to create courts of justice. It was not the intention of Congress, in enacting Republic Act No. 997, to authorize the transfer of powers and jurisdiction granted to courts of justice to officials to be appointed or offices to be created by the Reorganization Plan. The Court relied on its recent rulings in the series of cases including Corominas versus Labor Standards Commission, MCU versus Calupitan, Wong versus Carlim, and Balrodgan Company versus Fuentes.

On the third issue, because the jurisdictional grant relied upon by the trial court is void, the dismissal cannot stand. The order of dismissal was reversed and set aside, and the case was remanded to the court of origin for further proceedings.

Doctrine

First, the Legislature may not and cannot delegate its powers to legislate or to create courts of justice to any other agency of the Government. A reorganization plan issued by an executive body cannot create courts or confer jurisdiction on administrative offices.

Second, a provision of a reorganization plan that grants regional offices original and exclusive jurisdiction over money claims of laborers is null and void where the grant was made without authority by Republic Act No. 997. The plan cannot exceed the authority the statute confers.

Third, the regular courts retain the jurisdiction conferred on them by law; an invalid administrative grant cannot divest them of it. A dismissal grounded solely on such a void provision must be reversed.

Disposition

The Supreme Court reversed and set aside the order of dismissal and remanded the case to the court of origin for further proceedings, without costs. Pitogo prevailed on the jurisdictional question.

Remember This

The single line to memorize: the Legislature may not and cannot delegate its powers to legislate or create courts of justice to any other agency of the Government, so Section 25 of Reorganization Plan 20-A is void. Examiners use this case to test the limits of delegated legislative power and the rule that administrative reorganization plans cannot divest regular courts of jurisdiction conferred by law.