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NESTOR J. BALLADARES v. VS.PEAK VENTURES CORPORATION/EL TIGRE SECURITY

FACTS:

The security guards filed a complaint against their employer, Peak Ventures Corporation/El Tigre Security and Investigation Agency, for underpayment of wages. The Department of Labor and Employment found evidence of underpayments and non-compliance with the necessary employment records. A Notice of Inspection Result was issued to Peak Ventures, but they failed to correct the violations or file objections. A hearing was scheduled, and the complainants and Peak Ventures sought to implead Yangco Market Owners and Administrators Association (YMOAA) as a respondent. YMOAA opposed the inclusion, stating that they were not the employer of the complainants. The Regional Director ruled in favor of the complainants, declaring Peak Ventures and YMOAA jointly and severally liable for payment. Peak Ventures filed a motion for reconsideration, which was denied. They appealed to the Office of the Secretary of Labor, but the appeal was dismissed. Peak Ventures then brought the case to the Court of Appeals, which ruled in their favor, stating that the Regional Director had no jurisdiction over the case. The complainants appealed to the Supreme Court, questioning the CA's application of Article 129 of the Labor Code and the abandonment of the Servando's, Inc. v. Secretary of Labor case.

ISSUES:

  1. Whether the Department of Labor and Employment (DOLE) Regional Director has jurisdiction over money claims arising from employer-employee relations exceeding P5,000.

  2. Whether the case falls under the exception clause in Article 128(b) of the Labor Code, requiring endorsement to the appropriate Arbitration Branch of the NLRC.

  3. Whether or not the Regional Director has jurisdiction over the case considering that the claims exceeded P5,000.

  4. Whether or not the labor regulations officer's findings were properly considered by the Regional Director and the Secretary of Labor.

  5. Whether or not the documentary evidence presented by EBVSAI is sufficient to warrant the reversal of the Regional Director's order.

  6. Whether or not the re-computation of the awards claimed by EBVSAI is acceptable.

RULING:

  1. The DOLE Regional Director has jurisdiction over money claims arising from employer-employee relations exceeding P5,000. The authority of the DOLE, under Article 128, comes into play regardless of the monetary value of the claims involved. The powers and extent of authority of the DOLE are defined in Article 128 of the Labor Code, as amended by R.A. No. 7730. The Secretary of Labor or his duly authorized representatives are empowered to hear and decide any matter involving the recovery of any amount of wages and other monetary claims arising out of employer-employee relations at the time of inspection, even if the amount exceeds P5,000.

  2. The case does not fall under the exception clause in Article 128(b) of the Labor Code. In order to divest the DOLE Regional Director of jurisdiction, the following elements must be present: (a) the employer contests the findings of the labor regulations officer and raises issues thereon; (b) resolving such issues requires examination of evidentiary matters; and (c) such matters are not verifiable in the normal course of inspection.

  3. The Regional Director has jurisdiction over the case even if the claims exceeded P5,000 because such jurisdiction was exercised in accordance with Article 128(b) of the Labor Code and the case does not fall under the exception clause.

  4. The labor regulations officer's findings were properly considered by the Regional Director and the Secretary of Labor.

  5. The documentary evidence presented by EBVSAI was not sufficient to warrant the reversal of the Regional Director's order. The Secretary of Labor also doubted the veracity and authenticity of EBVSAI's documentary evidence.

  6. The re-computation of the awards claimed by EBVSAI is not acceptable as it failed to show from what source and on what basis the computations were made. The documents presented were not sufficient to re-compute the awards.

PRINCIPLES:

  • The DOLE Regional Director has jurisdiction over money claims arising from employer-employee relations exceeding P5,000, as defined in Article 128 of the Labor Code.

  • The exception clause in Article 128(b) requires that the employer contests the findings, raises issues, and presents evidentiary matters that are not verifiable in the normal course of inspection in order to divest the DOLE Regional Director of jurisdiction.

  • The liability of the principal and the contractor is joint and solidary.

  • In labor standards cases, the whole enforcement machinery of the Department of Labor and Employment (DOLE) exists to ensure the expeditious delivery of what legally belongs to the worker, free of charge.