First Batch - Molave vs Judge Laron, SMC vs NLRC, DY vs NLRC and PEPSI COLA vs Martinez
Labor Law II...
Molave Motor Sales vs. Judge Laron Facts: Petitioner is a corporation engaged in the sale and repair of motor vehicles.Private respondent is the sales manager of PLAINTIFF. At the pre-trial conference, the DEFENDANT raised the question of jurisdiction of the Court stating that PLAINTIFF's complaint arose out of employer-employee relationship, and he subsequently moved for dismissal. Such complaint was dismissed by the judge because it must be the juris of the LA and NLRC to decide cases on ER-EE relationship. However, although a controversy is between an employer and an employee, the Labor Arbiters have no jurisdiction if the Labor Code is not involved. In this case, PLAINTIFF had sued for monies loaned to DEFENDANT, the cost of repair jobs made on his personal cars, and for the purchase price of vehicles and parts sold to him. Those accounts have no relevance to the Labor Code. hence, the civil has the juris over the matter. Issue Whether or not there was still a relationship of employer and employee between the parties. Held The dismissal of the case below on the ground that the sum of money and damages sued upon arose from employer-employee relationship was erroneous. Claims arising from employer-employee relations are now limited to those mentioned in paragraphs 2 and 3 of Article 217. There is no difficulty in stating that those in the case below should not be faulted for not being aware of the last amendment to the frequently changing Labor Code. The claim of DEFENDANT that he should still be considered an employee of PLAINTIFF, because the latter has not sought clearance for his separation from the service, will not affect the jurisdiction of respondent Judge to resolve the complaint of PLAINTIFF. DEFENDANT could still be liable to PLAINTIFF for payment of the accounts sued for even if he remains an employee of PLAINTIFF. PEPSI-COLA VS MARTINEZ Facts: Respondent Abraham Tumala, Jr. was a salesman in the petitioner's company. In the annual “Sumakwel” contest conducted by the company, he was declared the winner of the “Lapu-Lapu Award” for his performance as top salesman of the year,an award which entitled him to a prize of a houseand lot. Petitioner company, despite demands,have unjustly refused to deliver said prize. It was alleged that petitioner company, in a manner oppressive to labor andwithout prior clearance from the Ministry of Labor, illegally terminated his employment. Hence, Tumala filed a complaint in the CFI that petitioner be ordered to deliver hisprize and topay his back salaries and separation benefits. Petitioner moved to dismiss the complaint ongrounds of lack of jurisdiction.
Respondent Tumala maintains that the controversy is triable exclusively by the court of general jurisdiction Issue: WON the court of general jurisdiction and not the Labor Arbiter that has exclusive jurisdiction over the recovery of unpaid salaries,separation and damages Held: NO SC ruled that the Labor Arbiter has exclusive jurisdiction over the case. Jurisdiction over the subjectmatter is conferred by the sovereign authority whichorganizes the court; and it is given by law. Jurisdiction is never presumed; it must beconferred by law in words that do not admit of doubt. Under the Labor Code, the NLRC has the exclusive jurisdiction over claims, money or otherwise, arisingfrom ER-EE relations, except those expressly excludedtherefrom. The claim for the said prize unquestionablearose from an ER-EE relation and, therefore, fallswithin the coverage of P.D. 1691, which speaks of “allclaims arising from ER-EE relations, unless expresslyexcluded by this Code. To hold that Tumala’s claim forthe prize should be passed upon by the regular courtsof justice would be to sanction split jurisdiction andmultiplicity of suits which are prejudicial to the orderlyof administration of justice. WHEREFORE, PETITION IS GRANTED. DY vs. NLRC Facts: Private Respondent Carlito H. Vailoces was themanager of the Rural Bank of Ayungon. He was also a director and stockholder of the bank. In 1983, a special stockholder’s meeting was called for the purpose of electing the members of the bank’s Board of Directors. Petitioner Lorenzo Dy was elected president. Vailoces was not reelected as bank manager. Vailoces filed a complaint for illegal dismissal and damages against Dy asserting that after obtaining control of the majority stock of the bank, called an illegal stockholder’s meeting and elected a Board of Directors controlled by him; and that he was illegally dismissed as manager, without giving him the opportunity to be heard first. Dy denied the charge and pointed out that Vailoces’ position was an electiveone, and he was not re-elected as bank manager because of the Board’s loss of confidence in himbrought about by his absenteeism and negligence in the performance of his duties. The Executive Labor Arbiter ruled thatVailoces was illegally dismissed because he wasnot afforded due process of law. NLRC affirmed the decision of the Labor Arbiter because of theappeal of the petitioners was filed late. Issue: Whether the election of the Directors were validly held. HELD: YES Under PD No. 902-A, “Controversies in the election orappointments of directors, trustees, officers ormanagers of such corporations, partnerships orassociations, are explicitly declared to be within theoriginal and exclusive jurisdiction of the Securities andExchange Commission.” In the CAB, it shows
that the controversy between theparties is intra-corporate in nature because it revolvesaround the election of directors, officers or managersof the Rural Bank of Ayungon, the relation betweenand among its stockholders, and between them andthe corporation. It is well settled that the decision of atribunal not vested with appropriate jurisdiction is nulland void.Therefore, the judgment of the Labor Arbiter and theNLRC are void for lack of jurisdiction. WHEREFORE, PETITION IS GRANTED SMC vs. NLRC Facts: Petitioner sponsored an Innovation Program which grant cash rewards to all “SMC employees who submit to the corporation ideas and suggestions found tobeneficial to the corporation. Private Respondent Rustico Vega, who is a mechanic of SMC submitted an innovation proposal which supposedto eliminate certain defects in the quality and tasteof the product “San Miguel Beer Grande.” Petitioner Corporation did not accept the said proposal and refused Mr. Vega’s subsequent demands for cash award. Hence, Vega filed a complaint .He argued that his proposal had been accepted bythe methods analyst and was implemented by theSMC and it finally solved the problem of theCorporation. Petitioner denied of having approved Vega’sproposal. It stated that said proposal was turneddown for “lack of originality” and could not achieve the desire result.Further, petitioner Corporation alleged that the LA had no jurisdiction.The LA dismissed the complaint forlack of jurisdiction because the claim of Vega is “not a necessary incident of his employment” and does not fall under Article 217 of the Labor Code. However the Labor Arbiter ordered petitioner to pay Vega P2,000 as “financial assistance.” Both parties assailed said decision of the Labor Arbiter. The NLRC set aside the decision of the Labor Arbiterand ordered SMC to pay complainant the amountof P60,000 Issue: Whether the Labor Arbiter and the Commission has jurisdiction over the money claim filed by private respondent HELD: NO The court ruled that the money claim of private respondent arose out of or in connection with his employment with petitioner. However, it is not enough to bring Vega’s money claim within the original and exclusive jurisdiction of LA. In the CAB, the undertaking of petitioner SMC to grantcash awards to employees could ripen into an enforceable contractual obligation on the part of petitioner SMC under certain circumstances. Hence,the issue whether an enforceable contract had arisen between SMC and Vega, and whether it has been breached, are legal questions that labor legislations cannot resolved because it’s recourse is the law on contracts.Where the claim is to be resolved not by reference tothe Labor Code or other labor relations statute or acollective bargaining agreement BUT by the general civil law, the jurisdiction over the dispute belongs tothe regular courts of justice and not to the LaborArbiter and NLRC. WHEREFORE, PETITION IS GRANTED