G.R. No. L-58133 March 26, 1982
Mercedes Aguda, Aurea Pedrozo, Josephine Caraang, Lilia Durwin, Lourdes Larin, Lerna Villablanca, and Bernabe Llarenas, Jr., petitioners, vs. Judge Amador T. Vallejos, as Judge of the Court of First Instance of Manila, Branch XXII, and Adamson Ozanam Educational Institution, Inc., represented by its President, Father Leandro Montañana, and Father Maximino Temprado, Vice-President for Financial Affairs and Personnel, respondents.

FACTS

The petitioners were employees of respondent Adamson Ozanam Educational Institution, Inc., working in its canteen from 1974 until their alleged abrupt dismissal on June 2, 1980. On June 27, 1980, they filed a complaint with the National Capital Region of the Ministry of Labor, claiming underpayment of wages, overtime, holiday pay, and violations of various presidential decrees. This labor case remained pending.
Subsequently, on July 2, 1980, the petitioners filed a separate civil complaint for recovery of actual, moral, and exemplary damages totaling P300,000 against the same institution in the Court of First Instance of Manila. The respondent judge granted the school’s motion to dismiss this civil case on July 22, 1980, ruling that the claim for damages fell under the exclusive jurisdiction of the Bureau of Labor Relations. The petitioners’ motion for reconsideration was denied, and the case was eventually dismissed without prejudice.

ISSUE

Whether the Court of First Instance has jurisdiction over the petitioners’ complaint for damages arising from their dismissal from employment.

RULING

The Supreme Court ruled that the Court of First Instance correctly dismissed the complaint for lack of jurisdiction. The legal logic is anchored on the provisions of Presidential Decree No. 1691, which amended Article 217 of the Labor Code and took effect on May 1, 1980. This decree restored to the Labor Arbiters and the National Labor Relations Commission (NLRC) the original and exclusive jurisdiction over all money claims of workers and all other claims arising from employer-employee relations. This jurisdiction expressly includes claims for moral and exemplary damages connected to a labor dispute, such as a dismissal.
The Court explained that while a prior law (P.D. No. 1367) had briefly divested labor tribunals of jurisdiction over such damages, P.D. No. 1691 reversed this policy. The legislative restoration of jurisdiction to labor arbiters was intended to avoid the inefficiencies and potential injustices of a dual-jurisdiction system. Allowing a separate civil action in the regular courts for damages stemming from an employment termination would result in duplicity of suits, splitting a single cause of action, and the risk of conflicting rulings from two different tribunals on essentially the same factual claim. Therefore, the petitioners’ claim for damages, being inextricably linked to their dismissal, must be consolidated with and adjudicated in the pending labor case. The petition was dismissed.