G.R. No. L-50096 April 15, 1988
KERIMA POLOTAN-TUVERA and ORIENTAL MEDIA, INC., petitioners, vs. HON. ABELARDO M. DAYRIT, as Presiding Judge of the Court of First Instance of Manila, Branch 39, and GO TIONG, respondents.

FACTS

Private respondent Go Tiong was dismissed from his employment as a translator by petitioner Oriental Media, Inc. He filed a complaint for illegal dismissal and various money claims, including moral damages, before the Ministry of Labor. While this labor case was pending arbitration, Go Tiong separately filed a complaint for moral and exemplary damages amounting to P950,000.00, plus attorney’s fees, against the petitioners before the Court of First Instance of Manila. The petitioners moved to dismiss the civil case, arguing that the regular court lacked jurisdiction because the claim for damages arose from the employer-employee relationship and was intrinsically linked to the pending labor case. The respondent judge denied the motion to dismiss, holding that the civil action was purely for indemnification of damages as alleged in the complaint.

ISSUE

Whether the regular court has jurisdiction to entertain a claim for moral and other damages filed by a dismissed employee against his former employer, which claim arises from the termination of employment.

RULING

The Supreme Court granted the petition and set aside the order of the respondent court. The Court ruled that the regular court had no jurisdiction over the claim for damages. The complaint clearly showed that the claim arose from acts attributed to the employer during the existence of the employment relationship, specifically the dismissal. At the time the civil case was filed, Presidential Decree No. 1367 was in effect, which provided that Labor Arbiters had exclusive jurisdiction over cases arising from employer-employee relations but expressly excluded claims for moral or other forms of damages from that jurisdiction. However, during the pendency of this case, Presidential Decree No. 1691 was promulgated, amending the Labor Code to restore to Labor Arbiters the original and exclusive jurisdiction over “all other claims arising from employer-employee relations.” The Court, applying its precedent in Atlas Fertilizer Corporation v. Navarro, held that P.D. 1691 is a curative statute intended to correct the jurisdictional split created by P.D. 1367. It was given retroactive effect to pending proceedings to avoid duplicity of suits, splitting a cause of action, and the possibility of conflicting decisions from two different tribunals on claims stemming from the same labor dispute. Consequently, the claim for damages filed by Go Tiong in the regular court was a matter falling within the exclusive jurisdiction of the Labor Arbiter. The respondent court was directed to dismiss the civil case.