BATONG BUHAY GOLD MINES, INC., Petitioner, v.

HONORABLE DIONISIO DELA SERNA IN HIS

CAPACITY AS THE UNDERSECRETARY OF THE DEPARTMENT OF LABOR AND EMPLOYMENT,
ELSIE ROSALINDA TY, ANTONIO MENDELEBAR, MA. CONCEPCION Q. REYES, AND THE OTHER
COMPLAINANTS * IN CASE NO. NCR-LSED-CI-2047-87; MFT CORPORATION AND SALTER
HOLDINGS PTY., LTD., Respondents.
(G.R. No. 86963 : August 6, 1999)

Facts of the Case:

A labor standard case of unpaid wages and other statutory benefits that were not given to the
private respondent employees by their company Batong Buhay Gold Mines, Incorporated. The
May 23, 1986 complaint was deliberated by the Labor Standards and Welfare Officers to the
Regional Director 1, wherein, as a result, it compelled the petitioner to pay for necessary fees
and liabilities over the case which was also affirmed when the matter reached to the
Undersecretary. The main contention of the petitioner was that the Regional Director had no
jurisdiction over the case and hence declared its Orders and other special sheriff actions null
and void. The respondent Undersecretary upheld that the jurisdiction of the Regional Director
fallen under Article 128(b), as amended by EO 111 of the Labor Code which states that “the
Secretary of Labor and Employment, or HIS DULY AUTHORIZED REPRESENTATIVES shall have
the power to issue compliance orders to give effect to the labor standards provisions of this
Code”.

Issues:

Whether or not the Regional Director had jurisdiction for enforcement power over the labor
standard case?

Held:

Citing Maternity Children’s Hospital vs. Secretary of Labor, the Court ruled that the complaint
over underpayment of wages is a labor standards case and is governed by Article 128(b) as
amended of the Labor Code.

The complaint was prior to the amendment. Still, the Court upheld that even Regional Directors
already had enforcement power of monetary claims under Presidential Decree 850 issued on
December 16, 1975 which transferred labor standard cases from the arbitration system to the
enforcement system. Hence, EO 111 (December 11, 1986) is a curative in character based on
legislative intent that is reflected in Policy Instructions 6 and 37 which empowers the Regional
Directors to resolve uncontested money claims in cases where an employer-employee
relationship exists.

In regards to money claims, there was a confusion in the decision in several cases after the
promulgation of EO 111. Subsequent law RA 6715, allows the Regional Directors to adjudicate
money claims subject to the conditions set forth in Article 2 of the said law, hence an
overlapping jurisdiction, to wit:

a) the claim arises from employer-employee relationship

b) claimant does not seek reinstatement
c) the money claim of each employee or househelper does not exceed P5,000

Finally, the Article 128(b), as amended by RA 7730 as curative in character also, which governs
the visitorial and enforcement powers of the Labor Secretary and his representatives.

Decision:

WHEREFORE, the petition is hereby GRANTED as to grave abuse of discretion to the Special
Sheriff. But upholding the jurisdiction of the Regional Director as AFFIRMED.