G.R. No. 89621 September 24, 1991
PEPSI COLA DISTRIBUTORS OF THE PHILIPPINES, INC., et al., petitioners, vs. HON. LOLITA O. GAL-LANG, et al., respondents.

FACTS

The private respondents were employees of Pepsi Cola. Suspected of complicity in the irregular disposition of empty bottles, the company filed a criminal complaint for theft against them, later substituted with a complaint for falsification. After preliminary investigation, the Municipal Trial Court dismissed the complaint, a dismissal affirmed by the Provincial Prosecutor. Meanwhile, after an administrative investigation, the company dismissed the employees on November 23, 1987. The employees filed an illegal dismissal case with the NLRC. Separately, on April 4, 1988, they filed a civil complaint for damages in the Regional Trial Court, alleging malicious prosecution arising from the criminal complaints.
The petitioners moved to dismiss the civil case, arguing jurisdiction lay with the labor arbiter under Article 217 of the Labor Code, as the matter involved employer-employee relations. The trial court initially granted the motion but, upon reconsideration, reinstated the complaint, holding it was distinct from the pending labor case.

ISSUE

Whether the Regional Trial Court has jurisdiction over the employees’ civil complaint for damages based on alleged malicious prosecution, or if such a claim falls under the exclusive jurisdiction of the labor arbiter.

RULING

The Supreme Court affirmed the trial court’s order, ruling it had jurisdiction. The Court clarified that not every dispute between an employer and an employee falls under labor arbiter jurisdiction. Jurisdiction under Article 217 requires a reasonable causal connection between the claim asserted and the employer-employee relationship itself. The civil action for damages stemming from malicious prosecution is intrinsically a civil dispute arising from a tort, governed by the Civil Code and the Revised Penal Code.
The claim does not involve unfair labor practice, wages, hours of work, terms and conditions of employment, or any other benefit under the Labor Code. It is based on the alleged wrongful act of the employer in filing baseless criminal charges, which the municipal court found intended to harass. This issue of whether the criminal prosecution was malicious is a matter outside the labor arbiter’s competence, as the applicable laws are the Revised Penal Code and civil law on damages. The Court cited precedents like Medina v. Castro-Bartolome and Singapore Airlines Ltd. v. Paño, which held that simple actions for damages based on tortious acts, lacking a clear nexus to employer-employee relations, are cognizable by regular courts.