G.R. No. L-24749 July 31, 1969
George W. Fleischer and Paz Lalk, plaintiffs-appellants, vs. Pamplona Plantation Company, Inc., defendant-appellee.

FACTS

Plaintiffs-appellants, spouses George W. Fleischer and Paz Lalk, filed a verified complaint in the Court of First Instance of Negros Oriental against defendant-appellee Pamplona Plantation Company, Inc. They sought to recover the value of accrued vacation and sick leaves (P8,000.00), half the value of a vacation allowance for first-class transportation to and from the West Coast, U.S.A. (P5,000.00), moral damages (P50,000.00 each), exemplary damages (P10,000.00 each), actual expenses (P1,000.00), and attorney’s fees (P10,000.00), all arising from the alleged illegal dismissal of George W. Fleischer as Manager and member of the Board of Directors of the defendant’s vast coconut plantation. The defendant corporation moved to dismiss the case on the ground that the court had no jurisdiction, arguing that the money claims arose from agrarian relations and thus fell under the original and exclusive jurisdiction of the Court of Agrarian Relations pursuant to Section 154 of the Agricultural Land Reform Code (Republic Act 3844). The trial court granted the motion to dismiss, prompting this appeal.

ISSUE

Whether or not the present claim for damages and value of accrued leaves and traveling allowances of appellant Fleischer as Manager of appellee company, without any prayer for reinstatement, may be considered as a “money claim arising from agrarian relations” falling within the original and exclusive jurisdiction of the Court of Agrarian Relations.

RULING

No. The Supreme Court reversed the appealed decision, denied the motion to dismiss, and ordered the case returned to the trial court for further proceedings. The Court held that the employment relationship between Fleischer as Manager and the agricultural enterprise (coconut plantation) did not constitute agrarian relations. Agrarian relations arise only where the parties stand in the relation of landlord and tenant or farm employer and farm employee or laborer, and one of the parties works on the land. The Court cited the case of Dequito v. Lopez, which held that claims of a dismissed security guard in an agricultural enterprise are not money claims arising from agrarian relations. The Court reasoned that Fleischer, as manager, was the alter ego of the corporation and an ordinary employee, not a farm laborer. His relationship with the company was governed by their contract, not by the tenancy laws designed to protect farm workers. The fundamental purpose of the tenancy laws was not intended to cover persons occupying positions of general managerial character in agricultural enterprises. Therefore, the claims were outside the exclusive jurisdiction of the Court of Agrarian Relations and within the jurisdiction of the regular courts.