With the Labor Arbiter or Regional Trial Court?
“A money claim is within the exclusive jurisdiction of the labor arbiter only if there is a ‘reasonable causal connection’ between the claim asserted and the employee-employer relation.
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“A money claim is within the exclusive jurisdiction of the labor arbiter only if there is a ‘reasonable causal connection’ between the claim asserted and the employee-employer relation.
Not every controversy or money claim between employer and employee is under the exclusive jurisdiction of the labor arbiter. A money claim is within the exclusive jurisdiction of the labor arbiter only if there is a "reasonable causal connection" between the claim asserted and the employee-employer relation. In the absence of such a link, the complaint will be cognizable by the regular courts of justice. (Pepsi Cola Distributors of the Philippines Inc. v. Hon. Gal-lang, G.R. No. 89621, 24 September 1991)
Take the case of Eviota v. Hon. Court of Appeals, et al. (G.R. No. 152121, 29 July 2003), where the employee abruptly resigned from the company barely a month after his employment and rejoined his former employer. This compelled the company to file a complaint for damages before the regional trial court, alleging that the employee violated the rule of giving a one-month advance notice in case of resignation.
The employee then filed a motion to dismiss the complaint on the grounds that the action for the company's damages was within the exclusive jurisdiction of the Labor Arbiter. The employee averred that the company's complaint for damages arose from or was in connection with his employer-employee relationship with the company or some aspect or incident of such relationship. The company opposed the motion, saying that while its claim for damages incidentally involved an employer-employee relationship, the claim was actually predicated on the employee's acts and omissions, which are separately and distinctly governed by the New Civil Code.
In sustaining the company's contention, the Supreme Court explained that actions between employees and employers 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 company's cause of action for damages was anchored on the employee's employment of deceit and of making the company believe that he would fulfill his obligation under the employment contract with assiduousness and earnestness. The employee made a 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 company to hire a replacement. The company was left in the lurch, and its corporate plans and programs were in jeopardy and disarray.
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The employee simply walked away from his employment with the company sans any written notice to the prejudice of the company, its operations and the conduct of its business. Thus, it is evident that the company's cause of action against the employee did not involve the provisions of the Labor Code of the Philippines and other labor laws but the New Civil Code. The fact that the company was the erstwhile employer of the employee under an existing employment contract before the latter abandoned his employment was merely incidental.
In the same vein, in Singapore Airlines Limited v. Paño (G.R. No. L-47739, 22 June 1983), the employer instituted a complaint against the employee for damages for wanton justice and refusal without just cause to report for duty and for having maliciously and with bad faith violated the terms and conditions of their agreement for a course of conversion training at the expense of the employer.
The Supreme Court held that the complaint must be instituted before the regular courts as it was a breach of a contractual obligation, which is intrinsically a civil dispute. As in the case of Eviota, the relief sought was not labor benefits demanded by workers generally taken cognizance of in labor disputes, such as payment of wages, overtime compensation, or separation pay.
From the foregoing, it is undeniable that filing a complaint with the proper forum is crucial to ensure that your case is heard by the appropriate authority and that your rights are properly preserved and protected throughout the legal process.
For more of Dean Nilo Divina's legal tidbits, please visit www.divinalaw.com. For comments and questions, please send an email to cabdo@divinalaw.com.
