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399 Digest Brokenshire Memorial Hospital, Inc. Vs Minister of Labor and Employment (1990)

This case originated from a complaint filed by a union representing employees of Brokenshire Memorial Hospital against the hospital for non-compliance with a wage order. The regional director found in favor of the employees. The hospital appealed arguing the regional director did not have jurisdiction. The Supreme Court ruled that based on recent amendments to the labor code, claims over 5,000 pesos fall under the exclusive original jurisdiction of the labor arbiter, not the regional director. It also noted the hospital was disputing findings and raising issues that required a more formal proceeding before the labor arbiter. The case was referred to the labor arbiter for resolution.

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145 views2 pages

399 Digest Brokenshire Memorial Hospital, Inc. Vs Minister of Labor and Employment (1990)

This case originated from a complaint filed by a union representing employees of Brokenshire Memorial Hospital against the hospital for non-compliance with a wage order. The regional director found in favor of the employees. The hospital appealed arguing the regional director did not have jurisdiction. The Supreme Court ruled that based on recent amendments to the labor code, claims over 5,000 pesos fall under the exclusive original jurisdiction of the labor arbiter, not the regional director. It also noted the hospital was disputing findings and raising issues that required a more formal proceeding before the labor arbiter. The case was referred to the labor arbiter for resolution.

Uploaded by

jovani ema
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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BROKENSHIRE MEMORIAL HOSPITAL, INC. VS.

MINISTER OF LABOR AND EMPLOYMENT


(182 SCRA 5 [1990])

FACTS:

This case originated from a complaint filed by private respondents, Brokenshire Memorial Hospital Employees
and Worker's Union-FFW, represented by Eduardo A. Afuan, against petitioner on September 21, 1984 with
the Regional Office of the MOLE, Region XI, Davao City for non-compliance with the provisions of Wage Order
No. 5.

After due hearing the Regional Director rendered a decision dated November 16, 1984 in favor of private
respondents. Judgment having become final and executory, the Regional Director issued a Writ of Execution
whereby some movable properties of the hospital (petitioner herein) were levied upon and its operating
expenses kept with the bank were garnished. The levy and garnishment were lifted when petitioner hospital
paid the claim of the private respondents (281 hospital employees) directly, in the total amount of
P163,047.50 covering the period from June 16 to October 15, 1984. After making said payment, petitioner
hospital failed to continue to comply with Wage Order No. 5 and likewise, failed to comply with the new Wage
Order No. 6 which took effect on November 1, 1984, prompting private respondents to file against petitioner
another complaint docketed as ROXI-LSED-14-85, which is now the case at bar.

After the complainants had filed their reply, petitioner filed a Motion for the Certification of the case to the
National Labor Relations Commission for a full-blown hearing on the matter, including the counterclaim
interposed that the complainants had unpaid obligations with the Hospital which might be offset with the
latter's alleged obligation to the former.

Issues having been joined, the Regional Director rendered a decision on April 12, 1985 in favor of the
complainants (private respondents herein) declaring that petitioner (respondent therein) is estopped from
questioning the acquisition of jurisdiction because its appearance in the hearing is in itself submission to
jurisdiction and that this case is merely a continuance of a previous case where the hospital already willingly
paid its obligations to the workers on orders of the Regional Office. On the matter of the constitutionality of
the Wage Order Nos. 5 and 6, the Regional Director declared that only the court can declare a law or order
unconstitutional and until so declared by the court, the Office of the Regional Director is duly bound to enforce
the law or order.

Aggrieved, petitioner appealed to the Office of the Minister of Labor, which dismissed the appeal for lack of
merit. A motion for reconsideration was likewise denied by said Office, giving rise to the instant petition.

ISSUE: Whether or not the Regional Director has jurisdiction over money claims of workers concurrent with
the Labor Arbiter.

RULING:

The SC ruled that, in view of the enactment of Republic Act No. 6715, approved on March 2, 1989, which
amended Art. 129 and Art. 217 of the Labor Code, and in consonance with the case of Briad Agro Development
Corp., as reconsidered, the instant case falls under the exclusive original jurisdiction of the Labor Arbiter.

It will be observed that what in fact conferred upon Regional Directors and other hearing officers of the
Department of Labor (aside from the Labor Arbiters) adjudicative powers, i.e., the power to try and decide, or
hear and determine any claim brought before them for recovery of wages, simple money claims, and other
benefits, is Republic Act 6715, provided that the following requisites concur, to wit:

1) The claim is presented by an employee or person employed in domestic or household service, or


househelper under the code;

2) The claimant, no longer being employed, does not seek reinstatement; and

3) The aggregate money claim of the employee or househelper does not exceed five thousand pesos
(P5,000.00).
In the absence of any of the three (3) requisites, the Labor Arbiters have exclusive original jurisdiction over all
claims arising from employer-employee relations, other than claims for employee's compensation, social
security, medicare and maternity benefits.

Considering further that the aggregate claims involve an amount in excess of P5,000.00, the SC finds it more
appropriate that the issue of petitioner hospital's liability therefor, including the proposal of petitioner that
the obligation of private respondents to the former in the aggregate amount of P507,237.57 be used to offset
its obligations to them, be ventilated and resolved, not in a summary proceeding before the Regional Director
under Article 128 of the Labor Code, as amended, but in accordance with the more formal and extensive
proceeding before the Labor Arbiter. Nevertheless, it should be emphasized that the amount of the
employer's liability is not quite a factor in determining the jurisdiction of the Regional Director. However, the
power to order compliance with labor standards provisions may not be exercised where the employer
contends or questions the findings of the labor regulation officers and raises issues which cannot be
determined without taking into account evidentiary matters not verifiable in the normal course of inspection,
as in the case at bar.

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