G.R. No. L-65377 May 28, 1984
MOLAVE MOTOR SALES, INC., petitioner, vs. HON. CRISPIN C. LARON, Presiding Judge of the Regional Trial Court of Pangasinan, Branch XLIV and PEDRO GEMENIANO, respondents.

FACTS

Petitioner Molave Motor Sales, Inc., a corporation engaged in vehicle sales and repair, filed a civil complaint against its sales manager, respondent Pedro Gemeniano, for the collection of a sum of money amounting to P33,890.38. The claim was based on various accounts allegedly incurred by Gemeniano, including purchases of vehicles and parts, repair jobs on his personal cars, and cash advances, as evidenced by invoices, vouchers, and promissory notes. In his Answer, Gemeniano denied the allegations and specifically denied under oath the authenticity of the attached documents. He also raised a counterclaim, asserting he should still be considered an employee as no clearance for his separation had been sought.
During pre-trial, Gemeniano moved to dismiss the case for lack of jurisdiction, contending the claim arose from an employer-employee relationship and thus fell under the exclusive jurisdiction of the Labor Arbiter and the National Labor Relations Commission (NLRC). The respondent Judge granted the motion, dismissing the case on the ground that the money claim indeed arose from such a relationship.

ISSUE

Whether the Regional Trial Court has jurisdiction over the complaint for collection of a sum of money filed by an employer against its employee, or whether jurisdiction lies with the Labor Arbiter under the Labor Code.

RULING

The Supreme Court granted the petition, ruling that the Regional Trial Court retains jurisdiction. The legal logic hinges on the nature of the cause of action. The Court clarified that not every dispute between an employer and an employee falls under labor jurisdiction. Jurisdiction is determined by the relief sought and the allegations in the complaint. Here, the claim was for payment of specific personal debts—loans, vehicle purchases, and car repairs—incurred by Gemeniano in his personal capacity. These are ordinary civil obligations arising from contract or quasi-contract, governed by the Civil Code, and do not involve claims for wages, overtime pay, separation benefits, or any right rooted in the Labor Code or the employment agreement.
The Court cited precedents, such as Medina vs. Castro-Bartolome and Singapore Airlines Limited vs. Paño, which established that where the Labor Code has no relevance to the reliefs sought, the civil courts retain jurisdiction. The amendment to Article 217 of the Labor Code by Batas Pambansa Blg. 227, which limited the Labor Arbiter’s jurisdiction over money claims to those specified (e.g., wages, separation pay), further supports this conclusion. The accounts sued upon have no relevance to the Labor Code; they are civil liabilities distinct from the employer-employee relationship. Therefore, the dismissal for lack of jurisdiction was erroneous. The respondent Judge was ordered to reinstate and adjudicate the case.