PEPSI COLA DISTRIBUTORS OF THE PHILIPPINES,
INC., represented by its Plant General Manager ANTHONY B. SIAN, ELEAZAR LIMBAB,
IRENEO BALTAZAR & JORGE HERAYA, petitioners, vs. HON. LOLITA O. GAL-LANG,
SALVADOR NOVILLA, ALEJANDRO OLIVA, WILFREDO CABAÑAS & FULGENCIO LEGO,
respondents.G.R. No. 89621 | September 24, 1991.
FACTS:
The private
respondents were employees of the petitioner who were suspected of complicity
in the irregular disposition of empty Pepsi Cola bottles. On July 16, 1987, the
petitioners filed a criminal complaint for theft against them but this was
later withdrawn and substituted with a criminal complaint for falsification of
private documents. On November 26, 1987, after a preliminary investigation, the
complaint was dismissed.
Meantime,
allegedly after an administrative investigation, the private respondents were
dismissed by the petitioner company on November 23, 1987. As a result, they
lodged a complaint for illegal dismissal with the Regional Arbitration Branch
of the NLRC. In addition, they instituted in the RTC a separate civil complaint
against the petitioners for damages arising from what they claimed to be their
malicious prosecution.
The
petitioners moved to dismiss the civil complaint on the ground that the trial
court had no jurisdiction over the case because it involved employee-employer
relations that were exclusively cognizable by the labor arbiter. The motion was
granted on February 6, 1989. On July 6, 1989, however, on reconsideration, the
reinstated the complaint, saying it was “distinct from the labor case for
damages now pending before the labor courts.”
ISSUE:
Whether the
trial court has jurisdiction over the case
RULING:
It must be
stressed that not every controversy involving workers and their employers can
be resolved only by the labor arbiters. This will be so only if there is a
“reasonable causal connection” between the claim asserted and employee-employer
relations to put the case under the provisions of Article 217. Absent such a
link, the complaint will be cognizable by the regular courts of justice in the
exercise of their civil and criminal jurisdiction.
In San
Miguel Corporation v. NLRC the Court observed:
It is the
character of the principal relief sought that appears essential, in this connection.
Where such .principal relief is to be granted under labor legislation or a
collective bargaining agreement, the case should fall within the jurisdiction
of the Labor Arbiter and the NLRC, even though a claim for damages might be
asserted as an incident to such claim.
x x x
Where the
claim to the principal relief sought is to be resolved not by reference to the
Labor Code or other labor relations statute or a collective bargaining
agreement but by the general civil law, the jurisdiction over the dispute
belongs to the regular courts of justice and not to the Labor Arbiter and the
NLRC. In such situations, resolution of the dispute requires expertise, not in
labor management relations nor in wage structures and other terms and
conditions of employment, but rather in the application of the general civil
law. Clearly, such claims fall outside the area of competence or expertise
ordinarily ascribed to Labor Arbiters and the NLRC and the rationale for granting
jurisdiction over such claims to these agencies disappears.
While
paragraph 3 above refers to “all money claims of workers,” it is not necessary
to suppose that the entire universe of money claims that might be asserted by
workers against their employers has been absorbed into the original and
exclusive jurisdiction of Labor Arbiters.
x x x
For it
cannot be presumed that money claims of workers which do not arise out of or in
connection with their employer-employee relationship, and which would therefore
fall within the general jurisdiction of the regular courts of justice, were
intended by the legislative authority to be taken away from the jurisdiction of
the courts and lodged with Labor Arbiters on an exclusive basis. The Court,
therefore, believes and so holds that the “money claims of workers” referred to
in paragraph 3 of Article 217 embraces money claims which arise out of or in
connection with the employer-employee relationship, or some aspect or incident
of such relationship. Put a little differently, that money claims of workers
which now fall within the original and exclusive jurisdiction of Labor Arbiters
are those money claims which have some reasonable causal connection with the
employer-employee relationship.
The case
now before the Court involves a complaint for damages for malicious prosecution
which was filed with the Regional Trial Court of Leyte by the employees of the
defendant company. It does not appear that there is a “reasonable causal
connection” between the complaint and the relations of the parties as employer
and employees. The complaint did not arise from such relations and in fact could
have arisen independently of an employment relationship between the parties. No
such relationship or any unfair labor practice is asserted. What the employees
are alleging is that the petitioners acted with bad faith when they filed the
criminal complaint which the Municipal Trial Court said was intended “to harass
the poor employees” and the dismissal of which was affirmed by the Provincial
Prosecutor “for lack of evidence to establish even a slightest probability that
all the respondents herein have committed the crime imputed against them.” This
is a matter which the labor arbiter has no competence to resolve as the
applicable law is not the Labor Code but the Revised Penal Code.
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