San Miguel Corporation vs

NLRC
G.R. NO. 80774
MAY 31, 1988
FACTS:

Petitioner Corporation sponsored an Innovation Program

which rewarded cash to SMC employees who will submit ideas and
suggestions beneficial to the corporation. Rustico Vega submitted his
proposal entitled “Modified Grande Pasteurization Process” and
claimed entitlement to the cash award. SMC denied utilizing such
proposal but Vega alleged otherwise and filed a complaint with the
NLRC which arbitrated against the Petitioner.
ISSUE:

WON the money claim of Vega falls within the

jurisdiction of the Labor Arbiter and the NLRC.
Ruling:

No, said money claim falls outside the jurisdiction

of said agencies. The jurisdiction of the NLRC is outlined in
Art. 217 of the Labor Code which includes in par. 3 “all
money claims of workers, including those based on
nonpayment or underpayment of wages, overtime
compensation, separation pay and other benefits provided
by law or appropriate agreement…”
Ruling:

While par. 3 refers to “all money claims of

workers,” it is not necessary to suppose that the entire
universe of money claims has been absorbed into the
jurisdiction of the NLRC. Par. 3 should not be read in
isolation with the context formed by par. 1 (unfair labor
practices), par. 2 (terms and conditions of employment), par.
4 (household services), par. 5 (prohibited activities).
Ruling:

The unifying element of pars. 1-5 is that they refer

to cases or disputes arising out of or in connection with an
employer-employee relationship. The scope of par. 3 is
clarified by its associated paragraphs wherein money claims
falling within the original and exclusive jurisdiction of the
NLRC are those which have some reasonable causal
connection with the employer-employee relationship.
END………

Thank You and Mabuhay!