Dai-Chi vs. Villarama
Dai-Chi vs. Villarama
Dai-Chi vs. Villarama
On July 29, 1993, Dai-Chi filed a complaint for damages with the Pasig RTC, Br 156, Pasig against Limjuco, a former employee.
Dai-Chi alleged that Limjuco violated paragraph five of their Contract of Employment, which provides:
That for a period of two (2) years after termination of service from EMPLOYER, EMPLOYEE shall not in any manner be connected,
and/or employed, be a consultant and/or be an informative body directly or indirectly, with any business firm, entity or undertaking
engaged in a business similar to or in competition with that of the EMPLOYER.
Dai-Chi claimed that Limjuco became an employee of Angel Sound Philippines Corporation, a corporation engaged in the same line of
business as that of Dai-Chi, within two years from January 30, 1992, the date of Limjuco's resignation.
Dai-Chi further alleged that Limjuco is holding the position of Head of the Material Management Control Department, the same position he
held while in the employ of Dai-Chi.
Dai-Chi sought to recover liquidated damages in the amount of P100,000.00, as expressly provided for in paragraph 7 of the contract.
RTC: ruled that it had no jurisdiction over the subject matter of the controversy because the complaint was for damages arising from employeremployee relations. Citing Article 217(4) of the Labor Code of the Philippines, as amended by R.A. No. 6715, it stated that it is the Labor
Arbiter which had original and exclusive jurisdiction over the subject matter of the case.
In this petition, Dai-Chi asks for the reversal of RTC's dismissal of the civil case, contending that the case is cognizable by the regular courts. It
argues that the cause of action did not arise from employer-employee relations, even though the claim is based on a provision in the
employment contract.
ISSUE: Whether Dai-Chi's claim for damages is one arising from employer-employee relations
RULING/RATIO: NO (Note: I guess Article 224 was still Article 217 at the time this was decided)
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 some 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 (Emphasis supplied).
San Miguel was cited in Ocheda v. Court of Appeals, (1992), where we held that when the cause of action is based on a quasi-delict or tort,
which has no reasonable causal connection with any of the claims provided for in Article 217, jurisdiction over the action is with the regular
courts.
We also applied the "reasonable causal connection rule" in Pepsi-Cola Distributors of the Philippines, Inc. v.Gallang, (1991), where we held
that an action filed by employees against an employer for damages for the latter's malicious filing of a criminal complaint for falsification of
private documents against them came under the jurisdiction of the regular courts.
The rationale behind the holdings in these cases is that the complaint for damages was anchored not on the termination of the
employee's services per se, but rather on the manner and consequent effects of such termination.
Cases decided under earlier versions of Article 217 were consistent also in that intrinsically civil disputes, even if these involve an employer
and his employee, are cognizable by the regular courts. In Medina vs. Castro-Bartolome, (1982), a civil complaint for damages against the
employer for slanderous remarks made against them, we upheld the regular court's jurisdiction after finding that the plaintiffs did not allege any
unfair labor practice, their complaint being a simple action for damages for tortious acts allegedly committed by the defendants. In Molave
Sales, Inc. v. Laron, (1984), we held that the claim of the plaintiff against its sales manager for payment of certain accounts and cash
advances was properly cognizable by the regular courts because "although a controversy is between an employer and an employee, the
Labor Arbiters have no jurisdiction if the Labor Code is not involved."
Limjuco also raises the issue of forum shopping. He asserts that the petition should be dismissed pursuant to Circular No. 28-91 because DaiChi merely "mentioned in passing a labor case between Dai-Chi and Limjuco which is being handled by Dai-Chi's other counsel". Limjuco is
referring to NLRC NCR Case No. 00-11-0689493 filed by him on November 8, 1993.
Dai-Chi asserts that the case before the Labor Arbiter was filed by Limjuco against Dai-Chi for alleged illegal dismissal, underpayment of
wages and non-payment of overtime and premium pay with prayer for moral and exemplary damages, to which Dai-Chi, through its other
counsel, "logically raised as one of its several counterclaims against Limjuco the liquidated damages mentioned in the contract of employment
between the parties"
Dai-Chi did not fail to disclose the pending labor case in the certification required under Circular No. 28-91. Thus, Dai-Chi cannot be
considered to have submitted a false certification warranting summary dismissal of the petition.
Dai-Chi did not commit forum shopping. It set up its counterclaim for liquidated damages merely as a defense against private Limjuco's
complaint before the Labor Arbiter.
ACCORDINGLY, the Orders of the Regional Trial Court dated September 20, 1993 and November 29, 1993 are SET ASIDE. The trial court
is ORDERED to continue with the proceedings in Civil Case No. 63448.