5 San Miguel vs. NLRC 1988 Innovation Contest
5 San Miguel vs. NLRC 1988 Innovation Contest
5 San Miguel vs. NLRC 1988 Innovation Contest
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THIRD DIVISION
FELICIANO, J.:
Title of Proposal
Mr. Vega at that time had been in the employ of petitioner Corporation for
thirteen (1 3) years and was then holding the position of "mechanic in the
Bottling Department of the SMC Plant Brewery situated in Tipolo, Mandaue
City.
In an Order 4 dated 30 April 1986, the Labor Arbiter, noting that the money
claim of complainant Vega in this case is "not a necessary incident of his
employment" and that said claim is not among those mentioned in Article 217
of the Labor Code, dismissed the complaint for lack of jurisdiction. However,
in a gesture of "compassion and to show the government's concern for the
workingman," the Labor Arbiter also directed petitioner to pay Mr. Vega the
sum of P2,000.00 as "financial assistance."
The Labor Arbiter's order was subsequently appealed by both parties, private
respondent Vega assailing the dismissal of his complaint for lack of
jurisdiction and petitioner Corporation questioning the propriety of the award
of "financial assistance" to Mr. Vega. Acting on the appeals, the public
respondent National Labor Relations Commission, on 4 September 1987,
rendered a Decision, 5 the dispositive portion of which reads:
SO ORDERED.
Applying the foregoing reading to the present case, we note that petitioner's
Innovation Program is an employee incentive scheme offered and open only
to employees of petitioner Corporation, more specifically to employees below
the rank of manager. Without the existing employer-employee relationship
between the parties here, there would have been no occasion to consider the
petitioner's Innovation Program or the submission by Mr. Vega of his
proposal concerning beer grande; without that relationship, private
respondent Vega's suit against petitioner Corporation would never have
arisen. The money claim of private respondent Vega in this case, therefore,
arose out of or in connection with his employment relationship with petitioner.
The next issue that must logically be confronted is whether the fact that the
money claim of private respondent Vega arose out of or in connection with
his employment relation" with petitioner Corporation, is enough to bring such
money claim within the original and exclusive jurisdiction of Labor Arbiters.
Applying the foregoing to the instant case, the Court notes that the SMC
Innovation Program was essentially an invitation from petitioner Corporation
to its employees to submit innovation proposals, and that petitioner
Corporation undertook to grant cash awards to employees who accept such
invitation and whose innovation suggestions, in the judgment of the
Corporation's officials, satisfied the standards and requirements of the
Innovation Program 10 and which, therefore, could be translated into some
substantial benefit to the Corporation. Such undertaking, though unilateral in
origin, could nonetheless ripen into an enforceable contractual (facio ut
des) 11 obligation on the part of petitioner Corporation under certain
circumstances. Thus, whether or not an enforceable contract, albeit implied
arid innominate, had arisen between petitioner Corporation and private
respondent Vega in the circumstances of this case, and if so, whether or not
it had been breached, are preeminently legal questions, questions not to be
resolved by referring to labor legislation and having nothing to do with wages
or other terms and conditions of employment, but rather having recourse to
our law on contracts.
SO ORDERED.