G.R. No. L-38088. August 30, 1974.
JOVITO N. QUISABA, petitioner, vs. STA. INES-MELALE VENEER & PLYWOOD, INC., et al., respondents.

FACTS

Petitioner Jovito N. Quisaba filed a complaint with the Court of First Instance of Davao against his employer, Sta. Ines-Melale Veneer & Plywood, Inc., and its vice-president. The complaint alleged that after 18 years of service as internal auditor, he was instructed to purchase logs, a task he deemed inconsistent with his position. Upon his refusal, he was temporarily relieved of his audit duties and warned that non-compliance would be grounds for dismissal. Quisaba characterized this demotion to a “servile and menial job” as a “clever and subterfugial dismissal” or constructive discharge. His complaint sought moral damages, exemplary damages, termination pay, and attorney’s fees, but notably did not pray for reinstatement or back wages.
The defendants moved to dismiss the complaint for lack of jurisdiction, contending that the National Labor Relations Commission (NLRC), established under Presidential Decree No. 21, had exclusive jurisdiction over the dispute. Quisaba opposed, presenting an opinion from an NLRC representative stating the Commission had no jurisdiction over claims for damages arising from employer-employee relations. Despite this disclaimer, the trial court granted the motion to dismiss, holding that the case fundamentally involved an employer-employee relationship. Quisaba elevated the case via certiorari.

ISSUE

Whether a complaint seeking solely moral damages, exemplary damages, termination pay, and attorney’s fees, arising from an alleged oppressive constructive dismissal, falls within the exclusive jurisdiction of the NLRC or the regular courts.

RULING

The Supreme Court ruled in favor of the petitioner, holding that the regular courts have jurisdiction. The Court clarified that the jurisdiction of the NLRC under P.D. No. 21 is limited to “matters involving employee-employer relations,” which primarily concern disputes over the existence or terms of the relationship itself, such as those that could lead to strikes or lockouts. Quisaba’s complaint was grounded not on the dismissal per se—as he did not seek reinstatement or back wages—but on the manner of dismissal and its injurious consequences.
The Court distinguished between the employer’s right to dismiss and the manner of its exercise. The cause of action was based on alleged violations of civil law, specifically Article 1701 (prohibiting oppression by capital or labor) and Article 21 (making a person liable for damages for acts contrary to morals, good customs, or public policy) of the Civil Code, with moral damages being recoverable under Article 2219(10). The suit was therefore intrinsically a civil dispute concerning the protection of Quisaba’s private interests as a member of society from alleged oppressive acts, not a labor dispute over an existing employer-employee relationship. Consequently, the order of dismissal was set aside and the case was remanded to the trial court for further proceedings.