GR 93396; (September, 1991) (Digest)
G.R. No. 93396 September 30, 1991
PHILIPPINE AMUSEMENT AND GAMING CORPORATION, petitioner, vs. THE COURT OF APPEALS, HON. ELIODORO B. GUINTO, in his capacity as Presiding Judge, Br. LVIII, RTC of Angeles City and JOEL MONTOYA, respondents.
FACTS
On May 3, 1988, the Philippine Amusement and Gaming Corporation (PAGCOR) terminated the services of its Table Supervisor, Joel Montoya, on the ground of loss of confidence. Montoya filed a complaint for damages and attorney’s fees with the Regional Trial Court (RTC) of Angeles City, alleging dismissal without due process. PAGCOR moved to dismiss, arguing the labor arbiter had exclusive jurisdiction over such money claims. The RTC denied the motion, holding that PAGCOR, as a government-owned corporation, belonged to the Civil Service, but that RTCs retained jurisdiction under their broad powers. The Court of Appeals affirmed, reasoning the complaint focused on the manner of dismissal, not the dismissal itself, thus constituting an ordinary civil action.
ISSUE
Whether the Regional Trial Court has jurisdiction over Montoya’s complaint for damages arising from his termination by PAGCOR.
RULING
No. The Supreme Court granted PAGCOR’s petition and ordered the dismissal of the civil case. The legal logic proceeds from the classification of PAGCOR and the nature of Montoya’s employment. Under Article IX(B), Section 2(1) of the 1987 Constitution , government-owned or controlled corporations with original charters are part of the Civil Service. PAGCOR, created by Presidential Decree No. 1869, possesses an original charter and is thus a Civil Service entity. Consequently, disputes concerning the employer-employee relationship of its personnel fall under the jurisdiction of the Civil Service Commission and the Merit Systems Protection Board, not the regular courts or labor arbiters.
The Court clarified that while the Civil Service authorities generally have jurisdiction, an exception exists where the action is based purely on general laws, like a tort claim under the Civil Code, and is not equivalent to a labor dispute. Montoya’s claim for damages, however, is inseparable from the validity of his termination—a factual issue requiring prior administrative determination. Since his position was classified as “confidential” under P.D. No. 1869, the propriety of his dismissal on grounds of lost confidence is primarily for the Civil Service authorities to resolve. Furthermore, Montoya failed to exhaust these administrative remedies. Therefore, the RTC lacked jurisdiction to entertain the complaint at that stage.