Pinag-Isang Lakas ng
mga Manggagawa sa LRT (PIGLAS), et al. v. COA
G.R. No. 263060
July 23, 2024
FACTS:
On June
8, 1984, Metro and LRTA entered into a management contract in consideration of
a P5M annual fee to be paid by LRTA to Metro. LRTA undertook to defray and
reimburse all the operating expenses of Metro. LRTA’s Board of Directors also
approved the wage increases and grant of benefits to the employees of Metro as
provided in the CBA between Metro and its employees. On June 9, 1989, the Manila
Electric Company sold its 499,990 Metro shares of stocks to LRTA. Consequently,
Metro became a wholly owned subsidiary of LRTA. Metro changed its corporate
name to Metro Transit Organization, Inc., but maintained its distinct and
separate personality. On July 25, 2000, the Union staged a strike over a
bargaining deadlock which paralyzed the operations of the LRT Line 1 System. To
put a halt to the strike, the Secretary of DOLE assumed jurisdiction over the
labor dispute and issued an RTWO. Malunes et al. claimed that they were not
notified of the non-renewal of the agreement, and that their dismissal was
without just cause and due process of law. The closure of Metro was not just a
clear defiance of the RTWO issued by the Secretary, but an act of unfair labor
practice. They likewise alleged that Metro and LRTA are one and the same
business entity insofar as their employment relations with them is concerned.
In fact, Metro represented itself as being wholly owned by LRTA in the CBA it
entered with the Union. LRTA denied the existence of an employer-employee
relationship between it and Malunes et al. It contended that it was created by
virtue of EO 603. It is principally tasked to administer the LRT Line 1
operations under the auspices of the DOTC. Thus, it has a personality separate
and distinct from Metro. Moreover, they were validly dismissed from work for
staging an illegal strike and defying the RTWO of the Secretary. The closure of
Metro is an authorized cause of their dismissal from employment. A complaint
for illegal dismissal and unfair labor practice with claims for moral and
exemplary damages and attorney’s fees. The Labor Arbiter held that they were
not dismissed for a just or authorized cause or that they were afforded the
opportunity to defend themselves. The NLRC dismissed the appeal for
nonperfection due to the failure of the Undersecretary of the DOTC and Charmain
of the Board of Directors of Metro to post the required bond. Metro’s motion
for reconsideration was subsequently denied by the appellate court. Consequently,
the Union and Malunes et al. appealed to the NLRC. During the mediation
conference, it was made clear that the approval of the COA must be sought first
via a Petition for Money Claims. The parties agreed to submit the enforcement
of the judgment award to the COA for approval through that petition. The COA
denied.
ISSUE:
Whether
or not the COA committed grave abuse of discretion amounting to lack or excess
of jurisdiction when it denied the money claims of Malunes et al. against LRTA.
HELD:
No.
Malunes et al., who were former employees of Metro, were dismissed from
employment due to LRTA’s nonrenewal of its Agreement with Metro. The COA did
not reverse nor nullify the final and executory ruling in G.R. 175460. It
merely echoed the Second Division’s pronouncement in G.R. No. 182928 that LRTA
cannot be held liable for the illegal dismissal claims of Malunes et al. simply
because the labor arbiter had no jurisdiction over LRTA when it heard the
illegal dismissal case. As a matter of cause, the NLRC also had no jurisdiction
over LRTA at the appellate level. Consequently, the labor arbiter’s decision
and all of NLRC’s subsequent actions on the case were a nullity for want of
jurisdiction, and as such, they never attained finality insofar as LRTA is
concerned.
As far
as the claim of illegal dismissal is concerned, we find that NLRC cannot
exercise jurisdiction over LRTA. The NLRC and Labor Arbiter erred when it took
cognizance of such matter. In Hugo v. LRTA, we have already addressed the issue
of jurisdiction in relation to illegal dismissal complaints. In the said case,
the employees of Metro filed an illegal dismissal and unfair labor practice
complaint against Metro and LRT A. We held that the Labor Arbiter and NLRC did
not have jurisdiction over LRTA, to wit: The Labor Arbiter and the NLRC do not
have jurisdiction over LRTA. Petitioners themselves admitted in their complaint
that LRTA "is a government agency organized and existing pursuant to an
original charter (Executive Order No. 603)" and that they are employees of
METRO.
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