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San Miguel V NLRC

The case discusses whether the Labor Arbiter and NLRC have jurisdiction over a money claim filed by an employee against his employer. The employee proposed an innovation to his employer's process and claimed a cash award for it being implemented. The employer denied approving or adopting the proposal. The Labor Arbiter dismissed the complaint for lack of jurisdiction but ordered financial assistance. The NLRC set aside this decision and ordered payment to the employee. The issue is if labor bodies have jurisdiction over the money claim.

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28 views1 page

San Miguel V NLRC

The case discusses whether the Labor Arbiter and NLRC have jurisdiction over a money claim filed by an employee against his employer. The employee proposed an innovation to his employer's process and claimed a cash award for it being implemented. The employer denied approving or adopting the proposal. The Labor Arbiter dismissed the complaint for lack of jurisdiction but ordered financial assistance. The NLRC set aside this decision and ordered payment to the employee. The issue is if labor bodies have jurisdiction over the money claim.

Uploaded by

JoeyBoyCruz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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San Miguel v NLRC

FACTS:

1. Mr. Vega was employed with SMC for 13yrs as mechanic in the Bottling Dept.
2. He passed an innovative proposal concerning the pasteurization of San Miguel Beer Grande in line with the
company’s program that whoever would submit Ideas and suggestions found to be beneficial to the
Corporation, he will be granted with cash awards.
3. However, SMC did not find the proposal acceptable and consequently refused Mr. Vega's subsequent
demands for a cash award
4. Vega filed a complaint alleging that his proposal "[had] been accepted by the methods analyst and
implemented by the Corporation [in] October 1980, and is thus, claiming entitlement for a cash prize.
5. SMC alleged that PR had no cause of action because it denied ever having approved or adopted Mr. Vega's
proposal as part of the Corporation's brewing procedure
a. SMC alleged further that LA had no jurisdiction, Mr. Vega having improperly bypassed the
grievance machinery procedure prescribed under the CBA, and available administrative remedies
provided under the rules of the Innovation Program

LABOR ARBITER:

1. DISMISSED Petitioners’ Complaint for lack of Jurisdiction


a. The money claim is not a necessary incident of his employment
b. said claim is not among those mentioned in Article 217 of the Labor Code
c. appealed to NLRC
2. ordered petitioner to pay Vega P2,000 as “financial assistance” as in a gesture of compassion and to show
the government’s concern for the working man

NLRC

1. LA’s decision was set aside.


2. Ordered SMC to pay Vega 60K

ISSUE: W/N the LA & NLRC has jurisdiction over the money claim filed by private respondent

HELD | ANSWER: YES

LAW: Art. 217 provides for the Jurisdiction of Labor Arbiters and the NLRC refer to cases or disputes arising out of
or in connection with an employer-employee relationship.

Sec. 3. All money claims of workers, including those based on non-payment or underpayment of wages, overtime
compensation, separation pay and other benefits provided by law or appropriate agreement, except claims for
employees' compensation, social security, medicare and maternity benefits;

APPLICATION:

In the case, The Court believes that the money claims of workers" referred to in paragraph 3 of Article 217 embraces
money claims which arise out of or in connection with the employer-employee relationship, or some aspect or
incident of such relationship.

In the CBA, the undertaking of petitioner SMC to grant cash awards to employees could ripen into an enforceable
contractual obligation on the part of petitioner SMC under certain circumstances. Hence, the issue whether an
enforceable contract had arisen between SMC and Vega, and whether it has been breached, are legal questions that
labor legislations cannot resolved because it’s recourse is the law on contracts.

CONCLUSION: Where the claim is to be resolved not by reference to the Labor Code or other labor relations statute
or a collective bargaining agreement BUT by the general civil law, the jurisdiction over the dispute belongs to the
regular courts of justice and not to the Labor Arbiter and NLRC.

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