6/8/2020
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claim.
On March 31, 1982, private respondent filed with the Labor Arbiter a complaint against
the petitioner for underpayment of wages and non-payment of overtime pay and
contractual bonus.
On May 1, 1982, while the case was still in the conciliation stage, Executive Order
(E.O.) No. 797 creating the Philippine Overseas Employment Administration (POEA)
took effect. Section 4(a) of E.O. No. 797 vested the POEA with "original and exclusive
jurisdiction over all cases, including money claims, involving employer-employee
relations arising out of or by virtue of any law or contract involving Filipino workers for
overseas employment."[2]
Despite E.O. No. 797, respondent Labor Arbiter proceeded to try the case on the
merits. On September 23, 1983, he rendered a Decision[3] in favor of private
respondent, the dispositive portion of which reads:
"WHEREFORE, judgment is hereby rendered ordering the respondent to pay
the complainant as follows:
1. The sum of US$2,496.00 in its peso equivalent on August 25, 1981 as
difference between his allowance as Service Driver as against his position as
Helper/Laborer;
2. The sum of US$1,000.00 in its peso equivalent as of the same date, as
his contractual bonus.
The complaints for non-payment/underpayment of overtime pay and unpaid
wages or commission are DISMISSED for lack of merit."[4]
Petitioner appealed to respondent National Labor Relations Commission (NLRC). It
questioned the jurisdiction of the Labor Arbiter over the case in view of the enactment
of E.O. No. 797.
In a Resolution dated July 17, 1991,[5] respondent NLRC dismissed the petitioner's
appeal and upheld the Labor Arbiter's jurisdiction. It ruled:
"To begin with, the Labor Arbiter has the authority to decide this case. On
May 29, 1978, the Labor Arbiters were integrated into the Regional Offices
under P.D. 1391. On May 1, 1980, P.D. 1691 was promulgated giving the
Regional Offices of the Ministry of Labor and Employment the original and
exclusive jurisdiction over all cases arising out of or by virtue of any law or
contract involving Filipino workers for overseas employment. There is no
dispute that the Labor Arbiter had the legal authority over the case on hand,
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/33758
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