Philippine Long Distance Telephone Company v. Honorable Ceferino Dulay
REITERATIONFacts
The Antecedents: Private respondents Rosemary Alferez and Teresita Mayordo, employees of petitioner Philippine Long Distance Telephone Co., Inc. (PLDT), were among seven employees PLDT sought to suspend and dismiss for alleged involvement in fraudulent stock certificate transactions. PLDT filed an application for clearance to do so with the Ministry of Labor. Procedural History: On October 20, 1979, private respondents, along with Anita Mayordo and Rey Alferez, filed a complaint with the Court of First Instance (CFI) of Cebu, Branch XVI, seeking damages arising from PLDT's conduct and practices allegedly violative of the Constitution and Civil Code provisions on torts. The complaint alleged two causes of action: (a) breach of commitment by PLDT in suspending and harassing the respondent-employees, and (b) damages for the death of Jose Mayordo, father of Rosemary and Teresita, who was an employee of PLDT killed in 1974. The CFI issued a restraining order. PLDT filed a motion to dismiss for prescription and lack of jurisdiction, which was denied. The Ministry of Labor granted PLDT's request for preventive suspension but left the determination of fraud to the grievance machinery. PLDT issued a memo suspending the respondent-employees indefinitely. The CFI cited petitioners Padilla and Melliza for indirect contempt and ordered them to desist from harassing the employees. The CFI denied PLDT's motion for reconsideration and reiterated its orders. The Petition: Petitioners challenged the CFI's jurisdiction, arguing that the case involved a labor dispute and thus fell under the exclusive jurisdiction of labor arbiters and the National Labor Relations Commission (NLRC). This Court issued a temporary restraining order.
Issue(s)
Whether the Court of First Instance has jurisdiction over the subject matter of Civil Case No. 437-L, specifically regarding the first cause of action concerning the suspension and threatened dismissal of the respondent-employees. Whether the Court of First Instance has jurisdiction over the subject matter of Civil Case No. 437-L, specifically regarding the second cause of action for damages arising from the death of Jose Mayordo. Whether the second cause of action for damages arising from the death of Jose Mayordo has prescribed. Whether the ruling in Quisaba v. Sta. Ines-Melale Veneer and Plywood, Inc. is applicable to the present case. Whether Presidential Decree No. 1367, as amended, divests the regular courts of jurisdiction over claims for moral damages arising from employer-employee relations, considering the subsequent enactment of Presidential Decree No. 1691. Whether equity allows the private respondents to file their action before the appropriate labor tribunal, even if the prescriptive period for the second cause of action had passed, given that regular courts were the proper forum at the time of filing.
Ruling
The Petition is GRANTED. The assailed Orders of the respondent court are SET ASIDE. Civil Case No. 437-L is DISMISSED without prejudice to the right of private respondents to file appropriate action before the proper administrative body in the Department of Labor and Employment. The Restraining Order previously issued by this Court is hereby made PERMANENT.
Ratio Decidendi
On the jurisdiction of the Court of First Instance regarding the first cause of action: The Court held that the nature of an action is determined by the averments in the complaint. The first cause of action, concerning the suspension and threatened dismissal of the respondent-employees, arose from an employer-employee relationship. This relationship places the case squarely within the exclusive jurisdiction of labor arbiters and the NLRC, not the regular courts. The Court emphasized that the connection between the two causes of action was tenuous and that the claim for damages for the death of Jose Mayordo did not alter the nature of the first cause of action. On the jurisdiction of the Court of First Instance regarding the second cause of action: While the second cause of action for damages due to the death of Jose Mayordo was purely civil, the Court clarified that this did not alter the nature of the first cause of action, which fell under the jurisdiction of labor tribunals. On the prescription of the second cause of action: The Court found that the second cause of action for damages for the death of Jose Mayordo had prescribed. Under Article 1146 of the Civil Code, actions upon an injury to the right of the plaintiff and upon a quasi-delict must be instituted within four years. Jose Mayordo died on June 29, 1974, making the prescriptive period expire on June 29, 1978. The complaint was filed on October 20, 1979, which was beyond the four-year prescriptive period. Furthermore, the private respondents had already received P9,000.00 as indemnity for the death, making them estopped from claiming further damages for the same incident. On the applicability of Quisaba v. Sta. Ines-Melale Veneer and Plywood, Inc.: The Court explicitly stated that the doctrine in Quisaba, which distinguished between the right to dismiss and the manner of its exercise, had been abandoned in subsequent cases, particularly in Primero v. IAC. The Court found the distinction in Quisaba to be tenuous and difficult to observe. The Court reasoned that the legality of the act of dismissal is intimately related to the legality of the manner by which it was performed, and that whatever tribunal has jurisdiction over illegal dismissal also has jurisdiction over claims for moral and exemplary damages arising from such dismissal. On the effect of Presidential Decree No. 1367 and subsequent amendments: The Court acknowledged that at the time the complaint was filed (October 20, 1979), Presidential Decree No. 1367 was in effect, which limited the jurisdiction of Labor Arbiters to cases duly indorsed by Regional Directors and excluded claims for moral and other damages. However, the Court pointed out that Presidential Decree No. 1691, which took effect during the pendency of the case, substantially reenacted Article 217 of the Labor Code, restoring the jurisdiction of Labor Arbiters and the NLRC over all kinds of damages in employer-employee relations cases. The Court held that P.D. 1691 is a curative statute with retrospective application to pending proceedings. Therefore, the CFI no longer had jurisdiction over the subject matter, which was now vested exclusively in the NLRC. On the possibility of filing the action before the appropriate labor tribunal based on equity: The Court noted that even if the prescriptive period for the second cause of action had passed, equity might allow the private respondents to file their action before the appropriate labor tribunal, as regular courts were the proper forum at the time of filing.
Main Doctrine
The nature of an action is determined by the averments in the complaint, and jurisdiction over the subject matter is determined by the said averments. While a claim for damages arising from an employer's conduct may appear civil, if it stems from an employer-employee relationship, it falls under the exclusive jurisdiction of labor tribunals, especially when amended laws retroactively vest such jurisdiction.