DAI-CHI ELECTRONICS MANUFACTURING CORPORATION,
petitioner, vs. HON. MARTIN S. VILLARAMA, JR., Presiding Judge, Regional Trial
Court, Branch 156, Pasig, Metro Manila and ADONIS C. LIMJUCO, respondents.G.R. No. 112940. November 21, 1994.
FACTS:
On July 29,
1993, petitioner filed a complaint for damages with the Regional Trial Court against
private respondent, a former employee. Petitioner alleged that private
respondent violated the non-compete clause of their Contract of Employment.
Respondent
court ruled that it had no jurisdiction over the subject matter of the controversy
because the complaint was for damages arising from employer-employee relations.
Citing Article 217(4) of the Labor Code of the Philippines, as amended by R.A.
No. 6715, respondent court stated that it is the Labor Arbiter which had
original and exclusive jurisdiction over the subject matter of the case.
ISSUE:
Whether or
not petitioner’s claim for damages is one arising from employer-employee
relations
RULING:
Petitioner
does not ask for any relief under the Labor Code of the Philippines. It seeks
to recover damages agreed upon in the contract as redress for private
respondent’s breach of his contractual obligation to its “damage and prejudice”.
Such cause of action is within the realm of Civil Law, and jurisdiction over
the controversy belongs to the regular courts. More so when we consider that
the stipulation refers to the post-employment relations of the parties.
Jurisprudence
has evolved the rule that claims for damages under paragraph 4 of Article 217,
to be cognizable by the Labor Arbiter, must have a reasonable causal connection
with any of the claims provided for in that article. Only if there is such a
connection with the other claims can the claim for damages be considered as
arising from employer-employee relations.
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