GR 155990; (September 2007) (Digest)
G.R. No. 155990 , September 12, 2007
Universal Aquarius, Inc. and Conchita Tan vs. Q.C. Human Resources Management Corporation
FACTS
Petitioner Universal Aquarius, Inc. engaged respondent Q.C. Human Resources Management Corporation to supply temporary workers for its chemical plant. The supplied workers formed a union, Obrero Pilipino, which declared a strike on December 19, 2000. The strikers picketed and barricaded Universal’s plant and the adjoining depot of co-petitioner Conchita Tan (Marman Trading), disrupting business operations. Universal and Tan filed a civil complaint for damages against the individual strikers and respondent Resources before the Regional Trial Court (RTC). The complaint alleged Resources supplied workers who turned into a “band of scoundrels,” disrupting operations and breaching the implied warranty of supplying law-abiding personnel.
Subsequently, Universal entered into an agreement with the union to end the labor dispute. Petitioners then filed a notice of dismissal against the individual striker defendants. Respondent Resources moved to dismiss the complaint against it, arguing the complaint stated no cause of action and that dismissal of the case against the strikers extinguished any liability against it as their alleged employer. The RTC denied the motion to dismiss, but the Court of Appeals reversed, dismissing the complaint for lack of cause of action.
ISSUE
Whether the Court of Appeals erred in dismissing the complaint against respondent Resources for lack of cause of action.
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed the dismissal. In a motion to dismiss based on lack of cause of action, the test is the sufficiency of the allegations in the complaint. The complaint’s core allegation was that the strikers, supplied by Resources, illegally picketed and barricaded the premises, causing business disruption. This anchored Resources’ liability on the principle of respondeat superior under Article 2180 of the Civil Code, making an employer subsidiarily liable for damages caused by employees acting within the scope of their assigned tasks.
However, the cause of action against Resources was derivative of and dependent on the liability of the individual strikers. When petitioners voluntarily dismissed the complaint against the principal tortfeasors (the strikers), the basis for holding Resources liable as an employer was extinguished. The dismissal of the case against the employees, without any reservation of rights against the employer, necessarily carried with it the dismissal of the case against the employer. Consequently, the complaint no longer stated a cause of action against Resources. The RTC’s persistence in proceeding against Resources after the strikers’ dismissal constituted grave abuse of discretion, correctly rectified by the Court of Appeals via certiorari.