Associated words

San Miguel Corporation vs National Labor Relations Commission

G.R. No. 80774
May 31, 1988
Feliciano, J.

Issue:
Whether, NLRC and Labor Arbiter has jurisdiction over the money claim of he
respondent

Facts:
Petitioner San Miguel Corporation (SMC) sponsored an Innovation Program which
grants cash reward to all its employees who could submit ideas and suggestions found to be
beneficial to the corporation.

Private respondent, Rustico Vega, a mechanic of the bottling department of SMC

submitted his proposal and claimed entitlement to the cash reward. However, the proposal was
rejected by SMC for lack of originality and even if implemented, said proposal would not
achieve its desired result.

Hence, the petitioner filed a complaint to the Minsitry of Labor and Employment in
Cebu. However, the Labor Arbiter dismissed the case for lack of jurisdiction. Upon raising the
issue to NLRC, the latter decided in favor of Vega, thus, raised the issue to the court.

Decision:
No, said money claim falls outside the jurisdiction of Labor Arbiter and NLRC. The
jurisdiction of said agencies is outlined in Article 217 of the Labor Code, wherein, Paragraph 3
of the aforecited article provides in part that it includes “all money claims of workers.” This,
however, does not mean all kinds of money claims. Par. 3 of Art. 217 should not be read in
isolation of other paragraphs of Art. 217. Applying the rule of Associated Words, Par. 1-5 of Art.
217 would refer to cases or disputes arising from an employer-employee relationship. Since, the
innovation program of SMC is not based on an employer-employee relationship but arose out of
or in connection with Vega’s employment relationship with SMC. Therefore, the NLRC and
Labor Arbiter do not have the jurisdiction over the issue raised.

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