GR 85197; (March, 1991) (Digest)
G.R. No. 85197; March 18, 1991
NESTLÉ PHILIPPINES, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, EUGENIA C. NUÑEZ, LIZA T. VILLANUEVA, EMMANUEL S. VILLENA, RUDOLPH C. ARMAS, RODOLFO M. KUA and RODOLFO A. SOLIDUM, respondents.
FACTS
The private respondents were employees of Nestlé Philippines, Inc. who availed of the company’s car loan policy. Under this policy, the company advanced the purchase price of a car, to be repaid through monthly salary deductions, with ownership retained by the company until full payment. The private respondents were subsequently dismissed from service. Nestlé demanded they either settle the remaining loan balances or return the vehicles. As they refused, the company filed a civil action for recovery of possession in the Regional Trial Court, which issued an order for the sheriff to take custody of the cars.
Pending their appeals before the NLRC regarding their separate complaints for illegal dismissal, the private respondents filed an urgent petition in the NLRC for a temporary restraining order. They sought to enjoin the cancellation of their car loans and the collection of amortizations until their illegal dismissal cases were resolved. The NLRC en banc granted the injunction, holding the loan cancellations and payments in abeyance.
ISSUE
Whether the NLRC committed grave abuse of discretion in issuing a writ of injunction to stop the enforcement of the car loan obligations, which arose from contract, pending resolution of the illegal dismissal cases.
RULING
Yes. The Supreme Court granted the petition for certiorari and annulled the NLRC’s resolution. The Court held that the NLRC’s power to issue injunctions under Article 218(e) of the Labor Code is exercisable only in connection with a “labor dispute” as defined in Article 212(l), which involves controversies concerning terms or conditions of employment or representation.
The dispute over the car loan agreements is not a labor dispute. It is a civil dispute arising from debtor-creditor relations founded on contract. The company’s demand for payment or return of the vehicles is an enforcement of a civil obligation, independent of the employer-employee relationship. Whether the private respondents were illegally dismissed or not, their contractual obligation to pay the loan or return the car remains. The rights and obligations under the car loan contracts are not intertwined with the issues in the illegal dismissal case and are properly enforceable through a separate civil action in the regular courts. Therefore, the NLRC exceeded its jurisdiction and gravely abused its discretion by issuing the injunction.