RTC has jurisdiction despite existence of employment relationship

Regular courts have jurisdiction over action for damages under Article 19 and 21 of Civil Code by employee against employer for improper deductions on her salary. (G.R. No. 199601, November 23, 2015).

Although the PCIB opted not to raise the issue before this Court, we find it prudent and imperative to justify why the RTC had jurisdiction to take cognizance of Josephine's complaint despite the fact that her cause of action arose because her employer arbitrarily deducted from her salary - an act expressly prohibited by our labor laws.

Article 224 [217] of the Labor Code provides that the Labor Arbiters have original and exclusive jurisdiction to hear and decide claims for actual, moral, exemplary, and other forms of damages arising from employer-employee relations. The legislative intent appears clear to allow Labor Arbiters to award to an employee not only the reliefs provided by our labor laws, but also moral and other forms of damages governed by the Civil Code. Specifically, we have mentioned, in fact, that a complaint for damages under Articles 19, 20, and 21 of the Civil Code would not suffice to keep the case without the jurisdictional boundaries of our labor courts -especially when the claim for damages is interwoven with a labor dispute.

Nevertheless, when the cause of action has no reasonable connection with any of the claims provided for in Article 224 of the Labor Code, jurisdiction over the action is with the regular courts. Here, since Josephine's cause of action is based on a quasi-delict or tort under Article 19 in relation to Article 21 of the Civil Code, the civil courts (not the labor tribunals) have jurisdiction over the subject matter of this case.

To be sure, the case of Singapore Airlines Ltd. v. Ernani Cruz PaƱo is enlightening: Upon the facts and issues involved, jurisdiction over the present controversy must be held to belong to the civil courts. While seemingly petitioner's claim for damages arises from employer-employee relations, and the latest amendment to Article 217 of the Labor Code under PD No. 1691 and BP Big. 130 provides that all other claims arising from employer-employee relationship are cognizable by Labor Arbiters, in essence, petitioner's claim for damages is grounded on the "wanton failure and refusal" without just cause of private respondent Cruz to report for duty despite repeated notices served upon him of the disapproval of his application for leave of absence without pay. This, coupled with the further averment that Cruz "maliciously and with bad faith" violated the terms and conditions of the conversion training course agreement to the damage of petitioner removes the present controversy from the coverage of the Labor Code and brings it within the purview of Civil Law. Clearly, the complaint was anchored not on the abandonment per se by private respondent Cruz of his job as the latter was not required in the Complaint to report back to work but on the manner and consequent effects of such abandonment of work translated in terms of the damages which petitioner had to suffer.
In the present case, Josephine filed a civil complaint for damages against the PCIB based on how her employer quickly concluded that she was negligent and hence arbitrarily started to deduct from her salary. Clearly, without having to dwell on the merits of the case, Josephine opted to invoke the jurisdiction of our civil courts because her right to fair treatment was violated.

The discussion in Quisaba v. Sta. Ines-Melale Veneer & Plywood, Inc. is just as relevant as it is illuminating on the present case, to wit: Although the acts complained of seemingly appear to constitute "matters involving employee-employer relations" as Quisaba's dismissal was the severance of a preexisting employee-employer relation, his complaint is grounded not on his dismissal per se as in fact he does not ask for reinstatement or backwages, but on the manner of his dismissal and the consequent effects of such dismissal. x x x The "right" of the respondents to dismiss Quisaba should not be confused with the manner in which the right was exercised and the effects flowing therefrom. If the dismissal was done anti-socially or oppressively, as the complaint alleges, then the respondents violated article 1701 of the Civil Code which prohibits acts of oppression by either capital or labor against the other, and article 21, which makes a person liable for damages if he willfully causes loss or injury to another in a manner that is contrary to morals, good customs or public policy, the sanction for which, by way of moral damages, is provided in article 2219, no. 10. (Cf. Phil. Refining Co. v. Garcia, L-21962, Sept. 27, 1966, 18 SCRA 107).

From the foregoing, the case at bar is intrinsically concerned with a civil dispute because it has something to do with Josephine's right under Article 19 of the Civil Code, and does not involve an existing employer-employee relation within the meaning of Article 224 of the Labor Code. Josephine's complaint was, therefore, properly filed with and exclusively cognizable by the RTC.

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