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FRANCISCO GUICO v. SECRETARY OF LABOR

FACTS:

The case began when the Office of the Regional Director, Department of Labor and Employment (DOLE), received a complaint against Copylandia Services & Trading for labor standards violations. Inspections revealed that twenty-one copier operators were underpaid and did not receive benefits. A hearing was conducted, resulting in the employees submitting a joint affidavit and individual waivers and quitclaims, claiming they were signed under duress. The Regional Director ruled in favor of the employees and ordered the petitioner to pay backwages.

The petitioner appealed, questioning the jurisdiction of the Regional Director and the computation of the monetary award. The petitioner also filed a motion to reduce the appeal bond and proposed holding the case in abeyance for a possible settlement. Later, a compromise agreement was reached between the petitioner and most employees, which was reported to the District Labor Officer.

ISSUES:

  1. Whether the Regional Director has jurisdiction over the complaint of the 21 employees, considering that their individual claims exceed the P5,000.00 limit.

  2. Whether the Regional Director erred in computing the monetary award without regard to the actual number of days and time worked by the employees.

  3. Whether the Regional Director erred in not giving credence to the Receipt, Waiver, and Quitclaim of the employees.

RULING:

  1. The Regional Director has jurisdiction over the complaint of the 21 employees, despite their individual claims exceeding the P5,000.00 limit. The jurisdiction of the Regional Director extends not only to cases where the claimant's monetary claim does not exceed P5,000.00, but also to cases where the employer is engaged in prohibited practices under Article 128 of the Labor Code, as amended.

  2. The Regional Director did not err in computing the monetary award without regard to the actual number of days and time worked by the employees. The backwages awarded were based on the violations committed by the petitioner, and the computation was within the Regional Director's discretion.

  3. The Regional Director did not err in not giving credence to the Receipt, Waiver, and Quitclaim of the employees. The employees claimed that they signed the Joint Affidavit and the waiver for fear of losing their jobs, and subsequently repudiated said waiver. The Regional Director found their claims credible and declared the purported Receipt, Waiver, and Quitclaim ineffective.

PRINCIPLES:

  • The jurisdiction of the Regional Director extends not only to cases where the claimant's monetary claim does not exceed P5,000.00, but also to cases where the employer is engaged in prohibited practices under Article 128 of the Labor Code, as amended.

  • The computation of backwages by the Regional Director is within their discretion and may be based on the violations committed by the employer.

  • The credibility of the employees' claims can be taken into account in determining the validity and effectiveness of any executed waiver or quitclaim.