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Ace Navigation Co. Inc. vs. Fernandez, G.R. No. 197309

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Case Digest

Case Title: ACE Navigation Co., Inc., Vela International Marine Ltd., and/or Rodolfo Pamintuan vs.
Teodorico Fernandez

G.R. No.: 197309

Date: October 10, 2012

Ponente: Justice Brion

Facts:

- Teodorico Fernandez, a seaman, filed a complaint for disability benefits against ACE Navigation Co., Inc.
and its co-defendants.

- The petitioners moved to dismiss the complaint, claiming that the labor arbiter lacked jurisdiction due
to the existence of a collective bargaining agreement (CBA) that provided for mandatory arbitration of
disputes.

- The labor arbiter denied the motion, asserting jurisdiction over money claims under the Migrant
Workers and Overseas Filipinos Act of 1995 (R.A. No. 8042).

- The NLRC upheld the labor arbiter's decision, leading the petitioners to seek a review from the Court of
Appeals (CA), which denied the petition on procedural and substantive grounds.

Issues:

1. Whether the CA erred in holding that the labor arbiter had jurisdiction over the case despite the
existing CBA.

2. Whether the provisions in the CBA provided for mandatory arbitration of disability claims.

Ruling:

1. Jurisdiction: The Supreme Court ruled that the voluntary arbitrator has original and exclusive
jurisdiction over Fernandez's disability claim, as it arose from his employment and was covered by a CBA
that provided for a grievance procedure and mandatory arbitration. The CA's conclusion that the labor
arbiter had jurisdiction was overturned.

2. CBA Interpretation: The Court found unequivocal language in the CBA that required the parties to
submit disputes to mandatory arbitration, despite the use of "may" in one section. The CBA's provisions
clearly mandated that unresolved disputes must be referred to the Grievance Resolution Committee,
and subsequently to the Mandatory Arbitration Committee.

Conclusion:

The Supreme Court granted the petition, setting aside the CA's decision and referring Fernandez's
disability claim to the appropriate grievance resolution mechanisms as outlined in the CBA.

Key Takeaways:

- Jurisdiction of Labor Arbitrators: When a CBA includes provisions for mandatory arbitration, disputes
arising from employment must be resolved through that arbitration process.

- Interpretation of CBA Language: Courts must interpret CBA provisions in their entirety, considering the
clear intent of the parties in their contractual obligations.

- Preference for Voluntary Dispute Resolution: The State's policy supports the resolution of labor
disputes through voluntary means, including arbitration, emphasizing the importance of adhering to
agreed dispute resolution procedures.

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