Labor arbiters’ money claims jurisdiction

A seafarer was hired by a maritime company as a laundry steward on its cruise ship. While serving on the ship, he suffered a knee injury that disabled him from performing his duties. A doctor certified that his injury was work-related. Another physician concluded that he was permanently disabled. Because of this, the seafarer filed a claim with his employer, which was denied.

This prompted him to file a complaint with the National Mediation and Conciliation Board. The board referred the matter to the Office of the Panel of Voluntary Arbitrators, whose jurisdiction was vehemently contested from the outset by the seafarer’s employer.

The panel ruled in favor of the seafarer, awarding him US$60,000 in damages. On appeal, the Court of Appeals reversed the ruling, declaring that the matter fell within the jurisdiction of the labor arbiter of the National Labor Relations Commission. The seafarer then elevated the case to the Supreme Court.

The Supreme Court sustained the Court of Appeals. It ruled:

“The issue to be resolved in this case is whether the Office of the Panel of Voluntary Arbitrators had jurisdiction over Tandayag’s complaint for permanent and total disability benefits, with claims for damages and attorney’s fees. Articles 224, 274 and 275 of the Labor Code, as amended, delineate the respective jurisdictions of labor arbiters and voluntary arbitrators: Article 224. Jurisdiction of the Labor Arbiters and the Commission — (a) Except as otherwise provided under this Code, the Labor Arbiters shall have original and exclusive jurisdiction to hear and decide, within 30 calendar days after submission of the case by the parties for decision without extension, the following cases involving all workers: (4) Claims for actual, moral, exemplary, and other forms of damages arising from employer-employee relations…

“Article 274. Jurisdiction of voluntary arbitrators or panel of Voluntary Arbitrators — The voluntary arbitrator or panel of voluntary arbitrators shall have original and exclusive jurisdiction to hear and decide all unresolved grievances arising from the interpretation or implementation of the collective bargaining agreement and those arising from the interpretation or enforcement of company personnel policies referred to in the immediately preceding Article.

“Article 275. Jurisdiction over Other Labor Disputes — The voluntary arbitrator or panel of voluntary arbitrators, upon agreement of the parties, shall also hear and decide all other labor disputes, including unfair labor practices and bargaining deadlocks. Pursuant to these provisions, workers’ claims for damages arising from employer-employee relations fall within the original and exclusive jurisdiction of labor arbiters.

“Meanwhile, voluntary arbitrators have original and exclusive jurisdiction over the interpretation and implementation of collective bargaining agreements, and the interpretation or enforcement of company personnel policies. Voluntary arbitrators may also hear and decide other labor disputes upon agreement of the parties.

“With regard to overseas Filipino workers, Section 10 of Republic Act 8042, as amended by Republic Act 10022, states that original and exclusive jurisdiction over their claims shall be vested in labor arbiters.

“In Estate of Dulay v. Aboitiz Jebsen Maritime Inc., this Court clarified that while claims arising out of an employer-employee relationship or by virtue of any law or contract involving Filipino workers for overseas deployment — including claims for actual, moral, exemplary, and other forms of damages — are generally within the jurisdiction of labor arbiters, if the dispute stems from the interpretation or implementation of a collective bargaining agreement, then Article 274 of the Labor Code shall apply.

“In this case, there was no collective bargaining agreement between the parties. … In finding that it had jurisdiction over petitioner’s complaint, the Panel relied on the existence of a submission agreement entered into by the parties. However, from the very beginning, petitioners challenged the jurisdiction of the Office of the Panel of Voluntary Arbitrators and consistently maintained that jurisdiction properly belongs to the labor arbiter.

“Even in their Motion for Reconsideration, petitioners continued to invoke the lack of jurisdiction of the Office of the Panel of Voluntary Arbitrators. Verily, since the Office of the Panel of Voluntary Arbitrators had no jurisdiction under the circumstances, its issuances are null and void ab initio.

“It is as if no decision and resolution were issued at all. Consequently, the assailed Decision and Resolution of the Office of the Panel of Voluntary Arbitrators have no legal force or effect.”

The facts and portions of the quoted (and redacted) decision are from Supreme Court G.R. 256183 (19 May 2025).