G.R. No. 118985 . June 14, 1999.
Coca Cola Bottlers, Phils., Inc., Victoriano Henson and Victor Aquino, petitioners, vs. Jose S. Roque, respondent.

FACTS

The case originated from the dismissal of private respondent Jose S. Roque by petitioner Coca Cola Bottlers, Phils., Inc. through its supervisor, Victoriano Henson. Following his termination, Roque was criminally charged with estafa but was subsequently acquitted. The acquittal was based not on a finding of innocence, but on the prosecution’s failure to prove his guilt beyond reasonable doubt.
Instead of filing a complaint for illegal dismissal with the Labor Arbiter, Roque filed a civil action for damages against the company and its officers before the Regional Trial Court (RTC) in 1989. The RTC ruled in favor of Roque, awarding him damages. This decision was affirmed by the Court of Appeals, prompting the petitioners to elevate the case to the Supreme Court via a petition for review.

ISSUE

The core issue is whether the Regional Trial Court had jurisdiction over Roque’s action for damages arising from his alleged illegal dismissal, or whether such claim falls under the exclusive original jurisdiction of the Labor Arbiter.

RULING

In his dissenting opinion, Chief Justice Davide, Jr. voted to grant the petition and reverse the Court of Appeals’ decision. The legal logic is anchored on the principle of jurisdiction and the prohibition against splitting a cause of action. Under Article 217 of the Labor Code, claims arising from employer-employee relations, including those for damages connected to illegal dismissal, fall within the original and exclusive jurisdiction of the Labor Arbiter. An employee illegally dismissed who also claims moral damages due to the manner of dismissal has a single, indivisible cause of action encompassing both the fact of illegal dismissal and the attendant damages.
By choosing to file solely a civil action for damages in the regular courts seven years after his dismissal, Roque improperly split his cause of action. He should have lodged a consolidated claim for reinstatement, back wages, and damages before the Labor Arbiter. Consequently, the RTC lacked jurisdiction over his complaint. Furthermore, even assuming regular courts had jurisdiction, his claim had already prescribed under Article 1146 of the Civil Code, which sets a four-year prescriptive period for actions arising from injury to rights. His filing in 1989 was well beyond the prescriptive period from his 1982 dismissal. His acquittal, being based on reasonable doubt, also did not establish a viable claim for malicious prosecution or damages under Articles 19, 20, or 21 of the Civil Code.