G.R. No. 116184 October 2, 1997
NATION BROADCASTING CORPORATION and ABELARDO YABUT, SR., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and DOUGLAS DE LA PAZ, respondents.
FACTS
Douglas de la Paz started as a radio announcer for petitioner Nation Broadcasting Corporation’s (NBC) station DXRB Butuan in 1979. On August 19, 1991, he was assigned as Officer-in-Charge/Acting Station Manager. On November 5, 1991, he was reverted to his position as a regular radio announcer. On November 12, 1991, he was placed under suspension for allegedly violating management directives. In January 1992, he filed a labor case. De la Paz claimed his demotion was without due process or just cause, was announced over the radio causing him embarrassment and health issues, and that upon his return from sick leave, his regular slot was taken and he was reassigned to other programs under threat of termination, which he argued constituted constructive dismissal. The Labor Arbiter ruled there was no constructive dismissal as his appointment as Station Manager was only in an acting capacity, and NBC was willing to reinstate him to his old position. However, the Labor Arbiter awarded him service incentive leave pay, 13th month pay, moral and exemplary damages, and attorney’s fees for being maligned over the air and receiving threatening memoranda. The NLRC modified the decision by deleting the awards for service incentive leave pay and 13th month pay as they were not pleaded, but affirmed the award of damages and attorney’s fees and ordered reinstatement or, if impractical, separation pay. Petitioners NBC and Abelardo Yabut, Sr. assail the NLRC Resolution, arguing that since there was no finding of constructive dismissal, the Labor Arbiter had no jurisdiction to award damages and attorney’s fees, and such claims fall under the jurisdiction of civil courts.
ISSUE
Whether the Labor Arbiter and the NLRC had jurisdiction to award moral and exemplary damages and attorney’s fees to Douglas de la Paz despite finding no constructive dismissal.
RULING
Yes. The Supreme Court dismissed the petition, ruling that the Labor Arbiter had original and exclusive jurisdiction over claims for damages arising from employer-employee relations under Article 217 of the Labor Code. The acts complained of—maligning de la Paz over the radio station’s air lanes and sending him threatening memoranda—arose out of the employer-employee relationship. The Court cited that labor arbiters have jurisdiction over money claims that have a reasonable connection with the employer-employee relationship. The NLRC did not commit grave abuse of discretion in affirming the award of damages and attorney’s fees, as the evidence showed petitioners acted with bad faith in the manner of de la Paz’s demotion. The Court also sustained the NLRC’s order for reinstatement or payment of separation pay as an equitable remedy, noting NBC had previously manifested willingness to accept de la Paz back to his old position.
