CBA
CBA
CBA
FACTS:
Astorga continued reporting for work. SMART issued a memorandum advising Astorga
of the termination of her employment on ground of redundancy,
Astorga filed a Complaint for illegal dismissal, non-payment of salaries and other
benefits with prayer for moral and exemplary damages against SMART.
SMART sent a letter to Astorga demanding that she pay the current market value of the
Honda Civic Sedan which was given to her under the company’s car plan program, or to
surrender the same to the company for proper disposition.
Astorga, however, failed and refused to do either, thus prompting SMART to file a suit
for replevin before the RTC which was subsequently denied.
Astorga moved to dismiss the complaint on grounds of (i) lack of jurisdiction; (ii) failure
to state a cause of action; (iii) litis pendentia; and (iv) forum-shopping. Astorga posited
that the regular courts have no jurisdiction over the complaint because the subject
thereof pertains to a benefit arising from an employment contract; hence, jurisdiction
over the same is vested in the labor tribunal and not in regular courts.
On March 29, 1999, the RTC issued an Order16 denying Astorga’s motion to dismiss the
replevin case.
As correctly pointed out, this case is to enforce a right of possession over a company
car assigned to the defendant under a car plan privilege arrangement. The car is
registered in the name of the plaintiff. Recovery thereof via replevin suit is allowed by
Rule 60 of the 1997 Rules of Civil Procedure, which is undoubtedly within the
jurisdiction of the Regional Trial Court.
Astorga filed a motion for reconsideration, but the RTC denied it on June 18, 1999.
Astorga elevated the denial of her motion via certiorari to the CA, which, in its February
28, 2000 Decision,19reversed the RTC ruling. Granting the petition and, consequently,
dismissing the replevin case, the CA held that the case is intertwined with Astorga’s
complaint for illegal dismissal; thus, it is the labor tribunal that has rightful jurisdiction
over the complaint. SMART’s motion for reconsideration having been denied,20 it
elevated the case to this Court.
ISSUE:
Whether or not the Court of Appeals was correct in holding that the regional trial court
has no jurisdiction over the complaint for recovery of a car which astorga acquired as
part of her employee benefit.
RULING:
SMART’s demand for payment of the market value of the car or, in the alternative, the
surrender of the car, is not a labor, but a civil, dispute. It involves the relationship of
debtor and creditor rather than employee-employer relations.
Replevin is a possessory action, the gist of which is the right of possession in the
plaintiff. The primary relief sought therein is the return of the property in specie
wrongfully detained by another person. It is an ordinary statutory proceeding to
adjudicate rights to the title or possession of personal property. The question of whether
or not a party has the right of possession over the property involved and if so, whether
or not the adverse party has wrongfully taken and detained said property as to require
its return to plaintiff, is outside the pale of competence of a labor tribunal and beyond
the field of specialization of Labor Arbiters.
The labor dispute involved is not intertwined with the issue in the Replevin Case. The
Court is not sanctioning split jurisdiction but defining avenues of jurisdiction as laid down
by pertinent laws.
The CA, therefore, committed reversible error when it overturned the RTC ruling and
ordered the dismissal of the replevin case for lack of jurisdiction.