Pinag-Isang Lakas ng mga Manggagawa sa LRT (PIGLAS), et al. v. COA

 

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.