GR 162420; (April, 2008) (Digest)
G.R. No. 162420 ; April 22, 2008
JAGUAR SECURITY AND INVESTIGATION AGENCY, petitioner, vs. RODOLFO A. SALES, JAIME L. MORON, MELVIN R. TAMAYO, JESUS B. SILVA, JR., DIONISIO C. CARANYAGAN, DANETH FETALVERO and DELTA MILLING INDUSTRIES, INC., respondents.
FACTS
Petitioner Jaguar Security and Investigation Agency is a security service contractor for respondent Delta Milling Industries, Inc. The individual respondents were security guards employed by Jaguar and assigned to Delta. They filed a labor case against both Jaguar and Delta for various monetary claims. The Labor Arbiter ruled in favor of the guards, holding Jaguar and Delta jointly and severally liable for the awarded benefits, which included wage differentials and holiday pay.
Jaguar filed a partial appeal with the NLRC, specifically questioning the failure to resolve its cross-claim against Delta for reimbursement of any amounts it would pay to the guards. The NLRC dismissed the appeal, stating it was not the proper forum and that Jaguar, as the direct employer, was principally liable. It directed Jaguar to file a separate civil action against Delta. The Court of Appeals affirmed this dismissal.
ISSUE
Whether the labor tribunals and the Court of Appeals erred in not resolving Jaguar’s cross-claim for reimbursement against its principal, Delta Milling Industries, Inc., within the same labor case.
RULING
No. The Supreme Court denied the petition, affirming the rulings of the lower tribunals. The Court explained that while Articles 106, 107, and 109 of the Labor Code establish the joint and several liability of the contractor (Jaguar) and the principal (Delta) to ensure workers receive statutory benefits, this liability is for the direct protection of employees. The right of reimbursement between the solidary debtors arises not from labor law but from civil law, specifically Article 1217 of the Civil Code.
Crucially, jurisdiction over a claim for reimbursement between the contractor and the principal lies with the regular courts, not the labor tribunals. Labor arbiters have jurisdiction only over cases arising from employer-employee relationships. The cross-claim for reimbursement involves a civil dispute between two entities with no such relationship; it is a separate issue from the labor dispute between the employees and their employers. Furthermore, the Court noted that Jaguar’s cause of action for reimbursement would only accrue upon its actual payment of the monetary award to the guards, an event which had not yet occurred. Therefore, the labor tribunals correctly declined to rule on the cross-claim, and Jaguar must pursue its claim for reimbursement in a separate civil action before the proper regular court.