6/8/2020
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‘Article 15. Bureau of Employment Services. (a) x x x
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(b) The Bureau shall have the original and exclusive jurisdiction over all
matters or cases involving employer-employee relations including money
claims, arising out of or by virtue of any law or contracts involving Filipino
workers for overseas employment, except seamen. The decisions of the
Bureau shall be final and executory subject to appeal to the Secretary of
Labor whose decision shall be final and inappealable.’
Considering that private respondent Jardin's claims undeniably arose out of
an employer-employee relationship with petitioner PSPC and that private
respondent worked overseas or in Saudi Arabia, the Bureau of Employment
Services and not the Labor Arbiter had jurisdiction over the case. x x x
Art. 15 was further amended by P.D. No. 1691 which took effect on May 1,
1990. Such amendment qualifies the jurisdiction of the Bureau of
Employment Services as follows:
‘(b) The regional offices of the Ministry of Labor shall have the original and
exclusive jurisdiction over all matters or cases involving employer-employee
relations including money claims, arising out of or by virtue of any law or
contracts involving Filipino workers for overseas employment except
seamen: Provided that the Bureau of Employment Services may, in the case
of the National Capital Region, exercise such power, whenever the Minister
of Labor deems it appropriate. The decisions of the regional offices or the
Bureau of Employment Services if so authorized by the Minister of Labor as
provided in this Article, shall be appealable to the National Labor Relations
Commission upon the same grounds provided in Article 223 hereof. The
decisions of the National Labor Relations Commission shall be final and
inappealable.’
Hence, as further amended, Art. 15 provided for concurrent jurisdiction
between the regional offices of the then Ministry of Labor and Bureau of
Employment Services ‘in the National Capital Region.’ It is noteworthy that
P.D. No. 1691, while likewise amending Art. 217 of the Labor Code, did not
alter the provision that Labor Arbiters shall have jurisdiction over all claims
arising from employer-employee relations ‘unless expressly excluded by this
Code.’
The functions of the Bureau of Employment Services were
subsequently assumed by the Philippine Overseas Employment
Administration (POEA) on May 1, 1982 by virtue of Executive Order
No. 797 by granting the POEA ‘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, including seamen.’ (Sec. 4
(a); Eastern Shipping Lines v. Philippine Overseas Employment
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/33758
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