J. A. POMEROY & COMPANY, INC., ET AL., PETITIONERS, VS. THE HON. COURT OF INDUSTRIAL RELATIONS, ET AL., RESPONDENTS.

Pomeroy versus Court of Industrial Relations

The Case

This is a petition for certiorari brought by J. A. Pomeroy and Company and its co-respondents against the Court of Industrial Relations. The employers ask the Supreme Court to reverse an order of the industrial court refusing to dismiss a complaint filed by Moises Valencia and thirteen other laborers for the collection of separation pay, with interest, attorney's fees, and moral and compensatory damages. The case matters because it draws the jurisdictional line between the Court of Industrial Relations and the ordinary courts: a claim for separation pay, standing alone, is a mere money claim, not a labor dispute.

Procedural History

Moises Valencia and thirteen other laborers filed a complaint in the Court of Industrial Relations, docketed as Civil Case Number 1200-V, dated February 27, 1959. The employers moved to dismiss on the ground that there was no employer-employee relationship between the parties and that the industrial court had no jurisdiction over a petition purely for separation pay. The Court of Industrial Relations denied the motion, relying on the case of Gomez versus North Camarines Lumber Company. The employers moved for reconsideration; the denial was affirmed by the court en banc. The employers then came to the Supreme Court on a petition for certiorari.

Facts

The petitioners in the court below were employed as laborers for various terms or periods between September 1954 and June 25, 1958. They were dismissed in the latter part of 1957 and in 1958. Their complaint, dated February 27, 1959, was filed after their employment had already ended.

The complaint alleged that the laborers had been unjustly separated, but it contained no claim or allegation that unfair labor practice had been committed. Neither did it allege that the separation had brought about a labor dispute of any sort. The prayer did not ask for reinstatement, notwithstanding the allegation of unjust separation.

On these facts the Supreme Court found no doubt that the action instituted below was merely for the recovery of separation pay.

Issues

• Whether or not the Court of Industrial Relations has jurisdiction to try and decide a complaint filed by laborers, after their employment has ended, purely for the collection of separation pay, with no claim for reinstatement and no allegation of unfair labor practice.
• Whether or not the doctrine of Gomez versus North Camarines Lumber Company, relied upon by the industrial court, still governs, in light of its subsequent express overruling.

Applicable Provisions

The decision does not quote a statute; it construes the jurisdictional principle laid down in PRISCO versus Court of Industrial Relations, which the Court adopts as the governing rule:

Analyzing these cases, the underlying principle, it will be noted in all of them, though not stated in express terms, is that where the employer-employee relationship is still existing or is sought to be reestablished because of its wrongful severance (as where the employee seeks reinstatement), the Court of Industrial Relations has jurisdiction over all claims arising out of, or in connection with employment, such as those related to the Minimum Wage Law and the Eight-Hour Labor Law. After the termination of the relationship and no reinstatement is sought, such claims become mere money claims, and come within the jurisdiction of the regular courts.

This principle bears directly on the case: the laborers' employment had ended and no reinstatement was sought, so their claim falls within the ordinary courts.

Ruling

On the first issue, the Court held that the Court of Industrial Relations had no jurisdiction. The complaint was filed on February 27, 1959, long after the employment relationship had terminated. It alleged unjust separation but claimed no unfair labor practice, alleged no labor dispute, and prayed for no reinstatement. What remained was a plain claim for separation pay, an ordinary money claim cognizable in the ordinary courts of justice.

On the second issue, the Court held that Gomez versus North Camarines Lumber Company had already been expressly overruled in PRISCO versus Court of Industrial Relations, where the Court declared the governing principle:

We are aware that in 2 cases, some statements implying a different view have been made, but we now hold and declare the principle set forth in the next preceding paragraph as the one governing all cases of this nature.

The Court also relied on Fookien Times Company versus Court of Industrial Relations, which held that a claim for separation pay and overtime compensation, with no claim for unfair labor practice or reinstatement, is an ordinary claim for money cognizable in the ordinary courts.

Doctrine

Where the employer-employee relationship is still existing, or is sought to be reestablished because of its wrongful severance, as where the employee seeks reinstatement, the Court of Industrial Relations has jurisdiction over all claims arising out of or in connection with employment. After the relationship has terminated and no reinstatement is sought, such claims become mere money claims and fall within the jurisdiction of the regular courts. A complaint for separation pay alone, without unfair labor practice, labor dispute, or reinstatement, is an ordinary money claim. Gomez versus North Camarines Lumber Company is overruled; PRISCO versus Court of Industrial Relations governs.

Disposition

The employers won: the Supreme Court set aside the order refusing to dismiss and ordered Civil Case Number 1200-V dismissed, without costs.

Remember This

Memorize the line: after the employment relationship ends and no reinstatement is sought, the claim becomes a mere money claim cognizable by the regular courts. Examiners use this case to test jurisdiction over separation pay and to test whether Gomez versus North Camarines Lumber Company still holds — it does not.