CASE DIGEST: Abad, et. al. v. RTC of Manila

 

G.R. No. L-65505 October 12, 1987

GABRIEL ABAD, PIO AGANON, MARIO ALARCIO, JOSE AQUINO, CESAR AURELIO, SOTERO BERNARDO, AURELIO CABRAL, JESUS CARREON, ABELARDO CARILLO, ET AL., petitioners, vs. REGIONAL TRIAL COURT OF MANILA, BRANCH LII-HON. DAVID G. NITAFAN and THE PHILIPPINE AMERICAN GENERAL INSURANCE COMPANY, INC., respondents.

 

FACTS:

The instant petition for certiorari originated from a complaint by the petitioners filed on August 18, 1978 against respondent PHILAMGEN for the enforcement of contract and recovery of loss of money basically praying for, among other things, payment of the money value of the respective accumulated sick leave with pay of the separated employees of respondent company either thru retirement, retrenchment or resignation.

Instead of filing an answer thereto, PHILAMGEN moved to dismiss the complaint, which the trial court granted.

After a denial of their motion to reconsider to the aforesaid order, petitioners filed before the SC a petition for Certiorari. The SC ordered for the case to be remanded to the trial court for further proceedings.

Unfortunately, fire destroyed the sala wherein the entire records of Civil case No. 117708 were kept. However, the records of the case were reconstituted on January 21, 1982 and the case was renumbered as Civil Case No. 82-1324. Thereafter, respondent Philamgen filed its Answer to the complaint. On January, 1983, judicial reorganization took place by the passage of Executive Order No. 864 and the case at bar was re-raffled to respondent Regional Trial Court of Manila, which was presided over by Judge David G. Nitafan. Respondent court motu proprio, dismissed the complaint in Civil Case No. 82-1324. declaring that it lacked jurisdiction over the subject made being money claims arising from employer-employee relations. Motion for reconsideration filed by petitioners was denied by respondent judge. Hence, this petition.

ISSUE:

Whether or not the trial court has jurisdiction over the case

RULING:

One of the important features in the Judiciary Reorganization effected through B.P. 129 is the addition of paragraph (6), Sec. 19, in defining the jurisdiction of Regional Trial Courts (which took the place of the abolished Courts of First Instance), which reading as follows:

In all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions.

A provision not found in Sec. 44 of the Judiciary Act of 1948. It was the intention of the legislative body to uncluttered the courts of cases which may be adjudicated, in the first instance, by officials or bodies exercising quasi-judicial adjudicatory powers like the Labor Arbiters or the National Labor Relations Commission a specialized body or bodies on labor related provisions and are not restricted by the technical rules of pleading and evidence.

The Regional Trial Courts of today are actually the same courts that functioned as Courts of First Instance before the Judiciary Reorganization Act (Batas Pambansa Bilang 129). There might have been a change in the name and in some incidental features but essentially, they are the same.

However, whereas before jurisdiction over money claims of laborers and employees appertained to Courts of First Instance, the same are now to be taken cognizance of by proper entities in the Department of Labor and Employment.

The rule of adherence of jurisdiction until a cause is finally resolved or adjudicated does not apply when the change in jurisdiction is curative in character. Thus in the instant case, there is nothing wrong in holding that Courts of First Instance /Regional Trial Courts no longer have jurisdiction over aforesaid monetary claims of labor.