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When does statutory construction come in

National Federation of Labor v. Honorable Carlito A. Eisma

G.R. No. L-61236
January 31, 1984


On March 5, 1982, the National Federation of Labor filed with the Ministry of Labor and Employment in
Zamboaga City a petition for direct certification as the sole exclusive collective bargaining representative of the
monthly paid employees of Zamboanga Wood Products, Inc. at its manufacturing plant in Lumbayao,
Zamboanga. On April 17, 1982, said employees charged Zambowood for underpayment of monthly living
allowances at the same office. On May 3, there was a notice of strike against Zambowood claiming illegal
termination of the Union president, unfair labor practice, non-payment of living allowances and employment
of oppressive alien management personnel without proper permit, with said strike commencing on May 23.
On July 9, 1982, Zambowood filed a complaint against the Union for damages for obstruction of
property with prayer for preliminary injunction and/or restraining order at the Court of First Instance as a result
of the picketers blocking the entry/exit points of the manufacturing division. Thereafter, the Union filed a
motion for dismissal and dissolution of the restraining order and opposition to the issuance of the writ of
preliminary injunction. The Union contended that the acts complained of were incidents of picketing and were
therefore the exclusive jurisdiction of the Labor Arbiter in accordance with BP Blg. 227. The motion was
dismissed on July 20 and the Union and its members were restrained and ordered to refrain from obstructing
Zambowoods use of its property.


Whether construction of the law is required to determine jurisdiction


No. The law may have vacillated as to jurisdiction regarding a claim for damages arising from
picketing or strike. But the most recent amendment thereto is clear and there is no room for construction.
Article 217 of the Labor Code provided that the labor arbiters have jurisdiction over such cases.
However, Presidential Decree No. 1367 amended this and provided "that the Regional Directors shall not
indorse and Labor Arbiters shall not entertain claims for moral and other forms of damages." Hence, damages
were under the jurisdiction of the ordinary courts. Issuance of PD 1691 afterwards reverted the jurisdiction to
the labor arbiters and covered all money claims of workers except claims for employee compensation, social
security, medicare and maternity benefits and other claims arising out of employer-employee relations.
Finally, Batas Pambansa Blg. 130 amended Paragraph (a), subparagraph 2 into "(2) those that involve wages,
hours of work and other terms and conditions of employment." Since there is no other provision in the
amendment that deals with the jurisdiction of labor arbiters on the matter of damages, PD 1691 subsists.
Jurisdiction is never presumed; it is given only by law. The law in this case is clear about the
jurisdiction conferred upon the labor arbiters and thus the court did not act with authority in deciding the case
brought to it. The courts have the duty to apply the law where it is plain and clear. If otherwise, then
construction and interpretation shall be resorted to.