MATERNITY CHILDREN’S HOSPITAL, represented by ANTERA L. DORADO,
President, Petitioner, v. THE HONORABLE SECRETARY OF LABOR AND THE REGIONAL DIRECTOR OF LABOR, REGION X, Respondents. Facts: Petitioner is a semi-government hospital which is partly subsidized by the Philippine Charity Sweepstakes Office. Respondent employees, filed a complaint with the Office of the Regional Director of Labor and Employment for underpayment of their salaries and ECOLAS (Emergency Cost of Living Allowance) The regional director sent two labor standard and welfare officers to investigate the claims. The officers confirmed there were underpayment of wages and ECOLAs of all the employees by the petitioner. The Regional Director issued an order directing the petitioner to pay. It was modified and affirmed by the Minister of Labor and Employment. Petitioner further questions the authority of the Regional Director to award salary differentials and ECOLAs to private respondents, alleging that the original and exclusive jurisdiction over money claims is properly lodged in the Labor Arbiter. That those in the reward also include not only employees currently working but also non-signatories of the complaint as well as those who are no longer employed with petitioner hospital. Issue: Whether or not the Regional Director has jurisdiction over the case Ruling: Social justice legislation, to be truly meaningful and rewarding to our workers, must not be hampered in its application by long-winded arbitration and litigation. Rights must be asserted and benefits received with the least inconvenience. Labor laws are meant to promote, not defeat, social justice. Labor Standards Labor standards refer to the minimum requirements prescribed by existing laws, rules, and regulations relating to wages, hours of work, cost of living allowance and other monetary and welfare benefits, including occupational, safety, and health standards Power of the Regional Director to Adjudicate Money Claims Under the present rules, a Regional Director exercises both visitorial and enforcement power over labor standards cases, and is therefore empowered to adjudicate money claims, provided there still exists an employer-employee relationship, and the findings of the regional office is not contested by the employer concerned. Adjudicatory powers of the regional director require the existence of employer-employee relationship The Ministry of Labor and Employment policies as well as E.O 111 reflects the intention enunciated in Policy Instructions Nos. 6 and 37 to empower the Regional Directors to resolve uncontested money claims in cases where an employer-employee relationship still exists. This intention must be given weight and entitled to great respect. However, there is no legal justification for the award in favor of those employees who were no longer connected with the hospital at the time the complaint was filed, having resigned therefrom in 1984. The enforcement power of the Regional Director cannot legally be upheld in cases of separated employees. Article 129 of the Labor Code, cited by petitioner is not applicable as said article is in aid of the enforcement power of the Regional Director; hence, not applicable where the employee seeking to be paid underpayment of wages is already separated from the service. His claim is purely a money claim that has to be the subject of arbitration proceedings and therefore within the original and exclusive jurisdiction of the Labor Arbiter. Visitorial and Enforcement power by the Regional Directors These two complementary powers to administer and to enforce the law are conferred by the Labor Code of the Philippines, as amended, on the Secretary of Labor and Employment or his duly authorized representatives, i. e., the DOLE Regional Directors. The visitorial grants to said DOLE officials, including labor and employment officers, access to employer's records and premises at any time of the day or night whenever work is being undertaken therein, and the right to copy there from such records, to question any employee and investigate any fact, condition or matter which may be necessary to determine violations or which may aid in the enforcement of the Labor Code and of any labor law, wage order or rules and regulations issued pursuant thereto (Art. 128 (a). The enforcement power to issue compliance orders to give effect to the labor standards provisions of the Labor Code and other labor legislation based on the findings of labor and employment officers or industrial safety engineers made in the course of inspection, and to issue writs of execution to the appropriate authority for the enforcement of their orders, except in cases where the employer contests the findings of the labor and employment officers and raises issues supported by documentary proofs which were not considered in the course of inspection." (Art. 128 (b).