G.R. No. L-58265 March 25, 1982
DIONISIO EBON, et al., petitioners, vs. JUDGE FELIZARDO S. M. DE GUZMAN and MARINDUQUE MINING AND INDUSTRIAL CORPORATION, respondents.

FACTS

Petitioners Dionisio Ebon, Marcelo Benocilla, Casiano Resota, Daniel L. Cutamora, and Rainerio Recentes were dismissed by respondent Marinduque Mining and Industrial Corporation (MMIC) in 1976. Each filed a complaint for reinstatement with backwages before the Labor Arbiter. Simultaneously, and prior to the issuance of Presidential Decree No. 1367, each petitioner also filed separate complaints for moral and exemplary damages against MMIC in the Court of First Instance (CFI) of Surigao del Norte, theorizing that such claims fell outside the jurisdiction of the National Labor Relations Commission (NLRC).
After the cases in the CFI progressed with the issues joined and hearings commenced, the trial judge, in a joint decision/order dated September 9, 1980, dismissed all five civil cases for lack of jurisdiction. The court ruled that claims for damages arising from dismissal fall within the exclusive jurisdiction of Labor Arbiters and the NLRC under Article 217 of the Labor Code, citing Garcia vs. Martinez. Petitioners filed a motion for reconsideration, which was denied on July 24, 1981.

ISSUE

Whether the Court of First Instance correctly dismissed the complaints for moral and exemplary damages for lack of jurisdiction, holding that such claims fall within the exclusive jurisdiction of the Labor Arbiters and the NLRC.

RULING

The Supreme Court dismissed the petition. Initially, the Court noted that petitioners availed of the wrong remedy; an appeal under Republic Act No. 5440 was the proper recourse, not a petition for certiorari and mandamus filed after the reglementary period for appeal had lapsed. Thus, the lower court’s decision had become final.
Nevertheless, to settle the jurisdictional issue, the Court affirmed the trial court’s dismissal. The Court explained that Article 217 of the Labor Code, as originally enacted and as restored by Presidential Decree No. 1691 (which nullified the intervening P.D. No. 1367), vested Labor Arbiters with original and exclusive jurisdiction over “all money claims of workers” and “all other claims arising from employer-employee relations.” This comprehensive grant of jurisdiction is broad enough to encompass claims for moral and exemplary damages arising from illegal dismissal. The legislative history confirms the intent to avoid duplicity of suits and conflicting findings by allowing a single tribunal to adjudicate all reliefs arising from the employment relationship. Consequently, the CFI correctly declined jurisdiction, as the claims were intrinsically linked to the employer-employee relationship and properly within the competence of the labor tribunals.