1.

Labor Arbiters Jurisdiction, in General

HAWAIIAN-PHILIPPINE CO. v GULMATICO, et al., G.R. No. 106231, November 16,
1994
FACTS:
National Federation of Sugar Workers-Food and General Trades, private respondent, filed
an action against Hawaiian Philippine Company for claims under RA 809 (the Sugar act of
1952). They alleged that they have never availed of the benefits due them under the said law.
Under such statute, the proceeds of any increase in participation shall be divided, in which 60%
for laborers and 40% for the planters.
Hawaiian, petitioner, argued that respondent Labor Arbiter Gulmatico has no jurisdiction
over the case considering their case which does not fall under Article 217 of the Labor Code. It
further contended that it has no employer-employee relationship.
ISSUE:
Whether or not public respondent Labor Arbiter has jurisdiction to hear and decide the
case against petitioner.
HELD:
While jurisdiction over controversies involving agricultural workers has been transferred
from the Court of Agrarian Relations to the Labor Arbiters under the Labor Code, said
transferred jurisdiction is however, not without limitations. The controversy must fall under one
of the cases enumerated in the Labor Code which was due or in connection with an employeremployee relationship.
However, there is no employer- employee relationship between petitioner and respondent
union. Hence, respondent labor arbiter has no jurisdiction to hear and decide the case against the
petitioner.
Wherefore, petition is granted.
2. Venue; Workers Option: Waiver
DAYAG, et al v CANIZARES, NLRC, G.R. NO. 124193, March 6, 1998
FACTS:
Petitioners were hired to work as tower crane operators by one Alfredo Young, a building
contractor doing business in the name of Youngs construction. In 1991, they were transferred to
Cebu City to work for Youngs Shoemart Cebu Project. Petitioner William Dayag asked
permission to go to Manila to attend family matters and was allowed to do so but was not paid
for January 23-30 due to his accountability for the loss of certain construction tools. The other
petitioners left due to harassment by young. Thereafter, petitioner banded together and filed a
complaint against Young before the NCR Arbitration Branch NLRC which was assigned to
Labor Arbiter Cenizares.
Further, Young filed a Motion to transfer the case to the Reginal Arbitration Brach,
Region VII of the NLRC. He contended that the case should be filed in Cebu City because it is
the location of the workplace of the petitioner. However, it was opposed by the petitioner on the
ground that they are both form Metro Manila and that they could not afford trips to Cebu, in
addition, they claimed that respondents main office is in Corinthian Garden in Quezon City.

Labor Arbiter Cenozares granted Youngs motion to transfer the case in Cebu. Petitioner
appealed to NLRC but such was dismissed. Hence, they filed a MFR and this time the
commission set aside its previous decision and remanded the case to the original arbitration
branch of the NCR for further proceedings. On the other hand, Young filed his own MFR and the
NLRC reinstated its first decision directing the transfer of the case to Cebu City.
ISSUE:
Whether the Labor Arbiter acted with grave abuse of discretion when it entertained
Youngs motion to transfer.
HELD:
No.
The SC ruled that litigations should, as much as possible, be decided on the merits and
not on technicalities. Petitioners were able to file an opposition on the motion to transfer case
which was considered by Labor Arbiter Cenizares. Hence, there is no showing that they have
been unduly prejudiced by the motions failure to give notice and hearing.
However, Young cannot derive comfort from this petition. The SC held that the question
of venue relates more to the convenience of the parties rather than upon the substance and merits
of the case. This is to assure convenience for the plaintiff and his witness and to promote the
ends of justice under the principle that the state shall afford protection to labor. The reason for
this is that the worker, being the economically-disadvantaged party, the nearest governmental
machinery to settle the dispute must be placed at his immediate disposal, and the other party is
not to be given the choice of another competent agency sitting in another place as this will
unduly burden the former.
WHEREFORE, petition is granted.