GR 154060; (August, 2005) (Digest)
G.R. No. 154060. August 16, 2005.
YUSEN AIR AND SEA SERVICE PHILIPPINES, INC., Petitioner, vs. ISAGANI A. VILLAMOR, Respondent.
FACTS
Petitioner Yusen Air and Sea Service Philippines, Inc., a freight forwarding company, employed respondent Isagani A. Villamor as a manager. Upon his resignation on February 1, 2002, Villamor immediately began working for Aspac International, a direct competitor. Yusen filed a complaint for injunction and damages in the Regional Trial Court (RTC) of Parañaque, alleging Villamor violated a company policy undertaking he signed. The undertaking prohibited employees, for two years post-resignation, from engaging in any business directly or indirectly competitive with Yusen.
Villamor moved to dismiss the RTC case, arguing it involved an employer-employee relationship and thus fell under the exclusive jurisdiction of the National Labor Relations Commission (NLRC) pursuant to Article 217 of the Labor Code. The RTC agreed and dismissed the complaint for lack of jurisdiction. Yusen’s motion for reconsideration was denied, prompting this petition.
ISSUE
Whether the Regional Trial Court has jurisdiction over petitioner’s complaint for injunction and damages based on an alleged breach of a post-employment contractual undertaking not to compete.
RULING
Yes, the RTC has jurisdiction. The Supreme Court set aside the RTC’s orders and remanded the case for trial on the merits of the claim for damages. The Court clarified that jurisdiction is determined by the allegations in the complaint. Yusen’s cause of action was not for a relief under the Labor Code but for damages based on a breach of a contractual obligation—the post-employment non-compete stipulation.
The legal logic is that for a case to fall under the exclusive jurisdiction of the labor arbiter under Article 217, the cause of action must have a reasonable causal connection with an employer-employee relationship. Here, the claim is founded on a quasi-delict or tort arising from the breach of a contractual term that governs conduct after the termination of employment. Such a claim is essentially civil in nature, pertaining to the realm of Civil Law concerning damages from breach of contract. The defenses raised in a motion to dismiss, such as the existence of an employer-employee relationship, cannot divest a court of jurisdiction which is properly vested based on the complaint’s allegations. Consequently, the RTC erred in dismissing the case and should proceed to adjudicate the unresolved claim for damages.