EDUARDO G. EVIOTA, petitioner, vs. THE HON.
COURT OF APPEALS, THE HON. JOSE BAUTISTA, Presiding Judge of Branch 136,
Regional Trial Court of Makati, and STANDARD CHARTERED BANK, respondentsG.R. No. 152121 | July 29, 2003
FACTS:
Sometime on
January 26, 1998, the respondent Standard Chartered Bank and petitioner Eduardo
G. Eviota executed a contract of employment under which the petitioner was employed
by the respondent bank as Compensation and Benefits Manager, VP (M21). However,
the petitioner abruptly resigned from the respondent bank barely a month after his
employment and rejoined his former employer.
On December
22, 1997, Eviota began negotiating with the Bank on his possible employment
with the latter. Taken up during these negotiations were not only his
compensation and benefit package, but also the nature and demands of his
prospective position. The Bank made sure that Eviota was fully aware of all the
terms and conditions of his possible job with the Bank.
The bank
alleges that his resignation, which did not comply with the 30-day prior notice
rule under the law and under the Employment Contract, was so unexpected that it
disrupted plans already in the pipeline, aborted meetings previously scheduled
among Bank officers, and forced the Bank to hire the services of a third party
to perform the job he was hired to do.
Aside from
causing no small degree of chaos within the Bank by reason of his sudden
resignation, Eviota made off with a computer diskette and other papers and documents
containing confidential information on employee compensation and other Bank
matters.
The bank
alleges that in his attempts to justify his hasty departure from the Bank and
conceal the real reason for his move, Eviota has resorted to falsehoods
derogatory to the reputation of the Bank. In particular, he has been maliciously
purveying the canard that he had hurriedly left the Bank because” it had failed
to provide him support. His untruthful remarks have fairly depicted the Bank as
a contract violator and an undesirable employer thus damaging the Bank’s reputation
and business standing.
Thus the
Bank filed a complaint for damages against Eviota with the trial court.
Petitioner
filed a motion to dismiss the complaint on the ground that the action for
damages of the respondent bank was within the exclusive jurisdiction of the
Labor Arbiter under paragraph 4, Article 217 of the Labor Code of the
Philippines, as amended. The petitioner averred that the respondent bank’s claim
for damages arose out of or were in connection with his employer-employee relationship
with the respondent bank or some aspect or incident of such relationship. The
respondent bank opposed the motion, claiming that its action for damages was
within the exclusive jurisdiction of the trial court. Although its claims for
damages incidentally involved an employer- employee relationship, the said
claims are actually predicated on the petitioner’s acts and omissions which are
separately, specifically and distinctly governed by the New Civil Code.
ISSUE:
Whether or
not the trial court has jurisdiction over the Bank’s complaint for damages
RULING:
Article 217
of the Labor Code of the Philippines, reads:
ART. 217.
Jurisdiction of 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 thirty (30) calendar days after the submission of the
case by the parties for decision without extension, even in the absence of
stenographic notes, the following cases involving all workers, whether
agricultural or nonagricultural:
1. Unfair labor practice cases;
2. Termination disputes;
3. If accompanied with a claim for reinstatement,
those cases that workers may file involving wages, rates of pay, hours of work
and other terms and conditions of employment;
4. Claims for actual, moral, exemplary
and other forms of damages arising from the employer-employee relations.
Case law
has it that the nature of an action and the subject matter thereof, as well as
which court has jurisdiction over the same, are determined by the material
allegations of the complaint and the reliefs prayed for in relation to the law involved.
Not every
controversy or money claim by an employee against the employer or vice-versa is
within the exclusive jurisdiction of the labor arbiter. A money claim by a
worker against the employer or vice-versa is within the exclusive jurisdiction
of the labor arbiter only if there is a “reasonable causal connection” between
the claim asserted and employee-employer relation. Absent such a link, the complaint
will be cognizable by the regular courts of justice.
Actions
between employees and employer where the employer-employee relationship is
merely incidental and the cause of action precedes from a different source of obligation
is within the exclusive jurisdiction of the regular court.
In this
case, the private respondent’s first cause of action for damages is anchored on
the petitioner’s employment of deceit and of making the private respondent believe
that he would fulfill his obligation under the employment contract with
assiduousness and earnestness. The petitioner volte face when, without the requisite
thirty-day notice under the contract and the Labor Code of the Philippines, as amended,
he abandoned his office and rejoined his former employer; thus, forcing the
private respondent to hire a replacement. The private respondent was left in a
lurch, and its corporate plans and program in jeopardy and disarray. Moreover,
the petitioner took off with the private respondent’s computer diskette, papers
and documents containing confidential information on employee compensation and
other bank matters. On its second cause of action, the petitioner simply walked
away from his employment with the private respondent sans any written notice,
to the prejudice of the private respondent, its banking operations and the
conduct of its business. Anent its third cause of action, the petitioner made
false and derogatory statements that the private respondent reneged on its
obligations under their contract of employment; thus, depicting the private respondent
as unworthy of trust.
It is
evident that the causes of action of the private respondent against the
petitioner do not involve the provisions of the Labor Code of the Philippines
and other labor laws but the New Civil Code. Thus, the said causes of action
are intrinsically civil. There is no causal relationship between the causes of action
of the private respondent’s causes of action against the petitioner and their
employer-employee relationship. The fact that the private respondent was the
erstwhile employer of the petitioner under an existing employment contract
before the latter abandoned his employment is merely incidental. In fact, the
petitioner had already been replaced by the private respondent before the
action was filed against the petitioner.
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