GR 178055; (July, 2014) (Digest)
G.R. No. 178055 , July 2, 2014
AMECOS INNOVATIONS, INC. and ANTONIO F. MATEO, Petitioners, vs. ELIZA R. LOPEZ, Respondent.
FACTS
Petitioner Amecos Innovations, Inc. hired respondent Eliza R. Lopez as a Marketing Assistant. Upon hiring, respondent allegedly refused to provide her SSS number and to have her contributions deducted, representing that she had other gainful work and was self-employed. Consequently, Amecos did not enroll her with the SSS or deduct contributions until her termination. Later, Amecos received a subpoena from the City Prosecutor due to a complaint filed by the SSS for delinquency in remitting contributions, including those for respondent. Amecos settled its obligations with the SSS. Petitioners then sent a demand letter to respondent for reimbursement of her share of the SSS contributions and expenses, and upon her failure to pay, filed a Complaint for sum of money and damages in the Metropolitan Trial Court (MeTC). They claimed actual damages for the amount paid to SSS, plus moral and exemplary damages and attorney’s fees, alleging respondent’s misrepresentation caused them damage. Respondent moved to dismiss, arguing the regular courts lacked jurisdiction as the claim arose from an employer-employee relationship. The MeTC dismissed the complaint for lack of jurisdiction, a decision affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA).
ISSUE
Whether the regular civil courts or the Labor Arbiter/National Labor Relations Commission (NLRC) has jurisdiction over claims for reimbursement and damages arising from misrepresentation related to employer-employee relations.
RULING
The Supreme Court denied the petition, ruling that jurisdiction lies with the Labor Arbiter under Article 217(a)(4) of the Labor Code. The Court held that the matter of SSS contributions necessarily flowed from the employer-employee relationship between the parties. Therefore, petitioners’ claims for damages arising from this relationship fall under the original and exclusive jurisdiction of the Labor Arbiter, not the regular courts. The Court noted that the Labor Arbiter has jurisdiction to award not only reliefs under labor laws but also damages governed by the Civil Code. Furthermore, the Court found that petitioners did not have a cause of action against respondent, as the employer has the primary legal obligation to remit SSS contributions, and any claim for reimbursement should be pursued in the proper labor forum.