GR 108961; (November, 1998) (Digest)
G.R. No. 108961 November 27, 1998
CITIBANK, N.A., petitioner, vs. COURT OF APPEALS (Third Division), and CITIBANK INTEGRATED GUARDS LABOR ALLIANCE (CIGLA) SEGA-TUPAS/FSM LOCAL CHAPTER No. 1394, respondents.
FACTS
Petitioner Citibank contracted El Toro Security Agency for security services, renewing the agreement yearly until its expiration on April 22, 1990. Respondent union CIGLA, representing El Toro guards assigned to Citibank, filed a request for preventive mediation with the National Conciliation and Mediation Board (NCMB) against Citibank, alleging unfair labor practice, dismissal of union members, and union busting. Citibank subsequently notified El Toro of non-renewal and hired a new security agency.
CIGLA converted its request into a notice of strike. The replaced guards, considering the non-renewal a lockout, threatened to strike and picket Citibank’s premises, loitering in groups near the bank. To prevent business disruption, Citibank filed a complaint for injunction and damages with the Regional Trial Court (RTC) of Makati. CIGLA moved to dismiss, asserting the RTC lacked jurisdiction as the dispute involved a labor matter and an employer-employee relationship with the bank. The RTC denied the motion, prompting CIGLA to elevate the case via certiorari to the Court of Appeals.
ISSUE
Whether the Regional Trial Court or the labor tribunal has jurisdiction over Citibank’s complaint for injunction and damages.
RULING
The Supreme Court ruled that the Regional Trial Court possesses jurisdiction. Jurisdiction is determined by the allegations in the complaint. Citibank’s complaint alleged a contractual relationship with an independent security agency, El Toro, not an employer-employee relationship with the individual guards. It further averred that the guards’ threatened strike and picketing would disrupt its business and cause irreparable injury. These allegations framed a cause of action for injunction and damages arising from tortious interference or similar acts, constituting an ordinary civil dispute.
The existence of a labor dispute and a potential employer-employee relationship were matters of defense raised by CIGLA. Such defenses do not automatically divest the court of jurisdiction, which is conferred by the nature of the action as pleaded in the complaint. The Court emphasized that the question of jurisdiction depends primarily on the plaintiff’s allegations, not the defenses interposed. Since the complaint’s averments presented a civil case, not a labor dispute, jurisdiction was properly vested in the RTC. The decision of the Court of Appeals was reversed, and the case was remanded to the RTC for further proceedings.