1. National Labor Relations Commission (NLRC)

National Labor Relations Commission (NLRC)

Concept

The National Labor Relations Commission (NLRC) is a labor adjudication body attached to the Department of Labor and Employment (DOLE) for program and policy coordination only. It operates through Regional Arbitration Branches, where Labor Arbiters hear cases at first instance, and the Commission Proper, whose divisions exercise appellate jurisdiction. The distinction identifies both where a case begins and where an appeal is heard. (Labor Code (amending Art. 213))¹

Governing provisions

The Labor Code establishes the Commission and provides for its divisions and regional branches. Republic Act No. 9347 amended the Labor Code provisions governing the NLRC. Special laws may also assign particular disputes to Labor Arbiters: for example, claims arising from an employment relationship or from a law or contract involving Filipino workers for overseas deployment fall within their original and exclusive jurisdiction under Republic Act No. 8042. (Labor Code (amending Art. 213))¹ (Republic Act No. 9347) (Sec. 10, Rep. Act No. 8042)²

Requisites / Rules

• Regional Arbitration Branches. Labor Arbiters exercise original jurisdiction over disputes assigned to them by law. They hear and decide the case; they are not a division of the Commission exercising appellate jurisdiction. (Labor Code (amending Art. 213))¹ (Sec. 10, Rep. Act No. 8042)²
• Commission Proper. The Commission exercises its adjudicatory powers through its divisions. Those divisions have exclusive appellate jurisdiction over cases within their respective territorial jurisdictions. The Commission sits en banc for rulemaking and policies affecting its administration and operations, not to act as another appellate division. (Labor Code (amending Art. 213))¹
• Meaning of “Commission.” Under the Labor Code, the term means the NLRC or any of its divisions, as the context requires. It must not be confused with the Labor Arbiter who decided the case in the first instance. (Labor Code (amending Art. 212))³ (Labor Code (amending Art. 213))¹

Key doctrines

Jurisdiction turns on the nature of the dispute and the law assigning it to a forum, not merely on the relief requested. Thus, claims for damages arising from picketing or a strike belong to Labor Arbiters rather than regular courts. Once the NLRC has acted, judicial review before the Court of Appeals proceeds through certiorari under Rule 65, directed at grave abuse of discretion; it is not an ordinary appeal on the merits. (NATIONAL FEDERATION OF LABOR and ZAMBOWOOD MONTHLY EMPLOYEES UNION v. Eisma, G.R. No. L-61236, 31 January 1984)⁴ (Airlines v. Yañez, G.R. No. 214662, 2 March 2022)⁵

Bar tip

Identify the forum in sequence: the Labor Arbiter at the Regional Arbitration Branch, the appropriate NLRC division on appeal, and the Court of Appeals on Rule 65 review. Do not treat the Commission en banc as an additional appellate level. (Labor Code (amending Art. 213))¹ (Airlines v. Yañez)⁵