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    The Supreme Court ruled that the Deputy Minister gravely abused his discretion in disclaiming jurisdiction over the issue of damages. The rule is that where a court has already obtained jurisdiction over a controversy, its jurisdiction is not affected by new legislation placing jurisdiction in another tribunal, unless the new statute expressly states or intends it to apply to pending cases. Here, the Labor Arbiter and NLRC had jurisdiction over the case, including damages, before PD 1367 was enacted removing jurisdiction over damages. As the case was already pending, PD 1367 did not apply retroactively to remove that jurisdiction.

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    32. Bengzon vs. Inciong

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    The Supreme Court ruled that the Deputy Minister gravely abused his discretion in disclaiming jurisdiction over the issue of damages. The rule is that where a court has already obtained jurisdiction over a controversy, its jurisdiction is not affected by new legislation placing jurisdiction in another tribunal, unless the new statute expressly states or intends it to apply to pending cases. Here, the Labor Arbiter and NLRC had jurisdiction over the case, including damages, before PD 1367 was enacted removing jurisdiction over damages. As the case was already pending, PD 1367 did not apply retroactively to remove that jurisdiction.

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    © All Rights Reserved
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    40 views2 pages

    Bengzon vs. Inciong

    Uploaded by

    I took her to my penthouse and i freaked it
    The Supreme Court ruled that the Deputy Minister gravely abused his discretion in disclaiming jurisdiction over the issue of damages. The rule is that where a court has already obtained jurisdiction over a controversy, its jurisdiction is not affected by new legislation placing jurisdiction in another tribunal, unless the new statute expressly states or intends it to apply to pending cases. Here, the Labor Arbiter and NLRC had jurisdiction over the case, including damages, before PD 1367 was enacted removing jurisdiction over damages. As the case was already pending, PD 1367 did not apply retroactively to remove that jurisdiction.

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    of 2

    Ricafort, Thea Joan Marie

    JD-4C

    Case
    BENGZON v. INCIONG
    Name
    Doctrine of Adherence to Jurisdiction/Continuity of Jurisdiction/Residual
    Topic
    Jurisdiction
    Case
    No. | G.R. Nos. L-48706-07; 91 SCRA 248, 256 | June 29, 1979
    Date
    Ponente ANTONIO, J.:
    “Where a court has already obtained and is exercising jurisdiction over a
    controversy, its jurisdiction to proceed to the final determination of the
    cause is not affected by new legislation placing jurisdiction over such
    Doctrine
    proceedings in another tribunal. The exception to the rule is where the
    statute expressly provides or is construed to the effect that it is intended to
    operate as to actions pending before its enactment.”
    https://lawphil.net/judjuris/juri1979/jun1979/gr_l_48706_07_1979.html
    Link

    RELEVANT FACTS:
     The following are the events prior to May 1, 1978, where PD No. 1367 was
    promulgated, which amended paragraph (3) of Article 217 of the Labor Code,
    basically providing that Regional Directors shall not indorse and Labor Arbiters
    shall not entertain claims for moral or other forms of damages:

    o [October 24, 1975] Petitioner filed a complaint for illegal dismissal with
    Regional Office No. IV of the Department of Labor against respondent Sta.
    Ines-Melale Veneer & Plywood Corporation and personally against its Vice-
    President, Robert V. Hyde (NLRC Case No. RB-IV-3168-75)
    o [March 31, 1976] The Labor Arbiter rendered a decision ordering Sta. Ines to
    pay complainant her separation pay while Hyde pays moral and exemplary
    damages.
    o Both parties appealed before the NLRC but the latter, remanded the case to
    the Labor Arbiter [June 1, 1976] for further proceedings on the ground that no
    jurisdiction was acquired by it over Hyde as respondent for failure to properly
    serve him with summons and a copy of the complaint.
    o [July 6, 1976] Petitioner filed an amended complaint with Regional Office No.
    IV of the Department of Labor and this was consolidated with the earlier case
    that was remanded to the Labor Arbiter.
    o [November 18, 1977] Labor Arbiter rendered a decision ordering respondent
    Sta. Ines-Melale Veneer & Plywood, Inc., and Robert V. Hyde to pay jointly
    and severally complainant Bengzon her separation pay and moral and
    exemplary damages. All the parties appealed the decision to the NLRC.
    o [February 21, 1978] NLRC rendered a decision en banc, ordering Sta. Ines to
    pay backwages, separation pay and moral and exemplary damages, denying
    complainant’s claim for reinstatement and absolving Hyde from any liability.
    Ricafort, Thea Joan Marie
    JD-4C

     [May 24, 1978] Respondent Sta. Ines filed an appeal with the Secretary of Labor
    from the decision en banc of the NLRC.
     [July 17, 1978] respondent Deputy Minister of Labor issued an Order affirming
    the decision of the NLRC but modifying the same by setting aside the award of
    damages on the ground of lack of jurisdiction in accordance with
    Presidential Decree No. 1367.
     Hence this petition before the SC.

    ISSUE: Whether or not the respondent Deputy Minister gravely abused his discretion
    in disclaiming jurisdiction on the issue of damages.
    RULING: YES.

    The rule is that where a court has already obtained and is exercising jurisdiction over
    a controversy, its jurisdiction to proceed to the final determination of the cause is not
    affected by new legislation placing jurisdiction over such proceedings in another
    tribunal. The exception to the rule is where the statute expressly provides, or is
    construed to the effect that it is intended to operate as to actions pending before its
    enactment. Where a statute changing the jurisdiction of a court has no retroactive
    effect, it cannot be applied to a case that was pending prior to the enactment of the
    statute.

    To require petitioner to file a separate suit for damages in the regular courts would be
    to "sanction split jurisdiction, which is prejudicial to the orderly administration of
    justice.

    RULING
    WHEREFORE, in view hereof, certiorari is granted and the respondent Deputy Minister
    of Labor is hereby directed to decide the appeal on the question of moral and exemplary
    damages, inviting attention to the fact that in their "Notice and Memorandum of Appeal",
    private respondent raised only questions of law and did not impugn the findings of fact
    of the NLRC as to the amount of damages. Costs against private respondent.

    SEPARATE OPINIONS
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    NOTES
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