GR 159482; (August, 2005) (Digest)
G.R. No. 159482 . August 30, 2005
NICASIO P. RODRIGUEZ JR., ET AL., Petitioners, vs. ANTONIO L. AGUILAR SR., Respondent.
FACTS
Respondent Antonio L. Aguilar Sr., a former Vice President and Compliance Officer of the Philippine Postal Savings Bank, Inc. (PPSBI), filed a complaint for damages with the Regional Trial Court (RTC) against the bank’s board of directors. He alleged that his demotion and subsequent dismissal were carried out in an “oppressive and abusive” manner because he had exposed anomalies within the bank. His original complaint included a prayer for reinstatement. The RTC initially dismissed the case for lack of jurisdiction, holding that it fell under the jurisdiction of the Labor Arbiter.
Unaware of this dismissal, the petitioners filed a Motion to Dismiss on the same jurisdictional ground. Respondent then filed an Amended Complaint, deleting his prayer for reinstatement and emphasizing only the allegedly oppressive manner of his dismissal to anchor his claim for moral and exemplary damages. The RTC admitted the amended complaint. Petitioners filed another Motion to Dismiss, which the court denied, subsequently declaring them in default for failure to file an answer. A judgment by default was rendered, awarding damages to respondent.
ISSUE
Whether the Regional Trial Court has jurisdiction over a complaint for moral and exemplary damages filed by an employee, where the damages are claimed to arise from the allegedly oppressive manner of his dismissal.
RULING
No. The Supreme Court ruled that the RTC has no jurisdiction over the case. The claim falls within the original and exclusive jurisdiction of the Labor Arbiter under Article 217 of the Labor Code. The Court clarified that jurisdiction is determined by the allegations in the complaint and the nature of the relief sought. The core allegation is that the damages resulted from the employer’s acts in relation to the dismissal. The fact that the amended complaint deleted the prayer for reinstatement and focused solely on the “oppressive manner” of dismissal is a mere artifice to circumvent the jurisdiction of the labor tribunal.
Claims for damages arising from employer-employee relations, including those grounded on the manner of dismissal, are intrinsically connected to the labor dispute. They do not cease to be a labor claim simply because the employee prays only for moral and exemplary damages. To hold otherwise would allow the easy erosion of the Labor Arbiter’s exclusive jurisdiction. Consequently, the RTC should have dismissed the amended complaint for lack of jurisdiction. The Court of Appeals’ decision was reversed and set aside, and the complaint before the RTC was dismissed.