Molave Motor Sales vs.

Judge Laron
Facts:
Petitioner is a corporation engaged in the sale and repair of motor
vehicles.Private respondent is the sales manager of PLAINTIFF. At the pre-trial
conference, the DEFENDANT raised the question of jurisdiction of the Court
stating that PLAINTIFF's complaint arose out of employer-employee
relationship, and he subsequently moved for dismissal. Such complaint was
dismissed by the judge because it must be the juris of the LA and NLRC to
decide cases on ER-EE relationship. However, although a controversy is
between an employer and an employee, the Labor Arbiters have no
jurisdiction if the Labor Code is not involved. In this case, PLAINTIFF had sued
for monies loaned to DEFENDANT, the cost of repair jobs made on his
personal cars, and for the purchase price of vehicles and parts sold to him.
Those accounts have no relevance to the Labor Code. hence, the civil has the
juris over the matter.
Issue
Whether or not there was still a relationship of employer and employee
between the parties.
Held
The dismissal of the case below on the ground that the sum of money and
damages sued upon arose from employer-employee relationship was
erroneous. Claims arising from employer-employee relations are now limited
to those mentioned in paragraphs 2 and 3 of Article 217. There is no difficulty
in stating that those in the case below should not be faulted for not being
aware of the last amendment to the frequently changing Labor Code.
The claim of DEFENDANT that he should still be considered an employee of
PLAINTIFF, because the latter has not sought clearance for his separation
from the service, will not affect the jurisdiction of respondent Judge to resolve
the complaint of PLAINTIFF. DEFENDANT could still be liable to PLAINTIFF for
payment of the accounts sued for even if he remains an employee of
PLAINTIFF.
PEPSI-COLA VS MARTINEZ
Facts:
Respondent Abraham Tumala, Jr. was a salesman in the petitioner's company.
In the annual Sumakwel contest conducted by the company, he was
declared the winner of the Lapu-Lapu Award for his performance as top
salesman of the year,an award which entitled him to a prize of a houseand
lot. Petitioner company, despite demands,have unjustly refused to deliver
said prize. It was alleged that petitioner company, in a manner oppressive to
labor andwithout prior clearance from the Ministry of Labor, illegally
terminated his employment.
Hence, Tumala filed a complaint in the CFI that petitioner be ordered to
deliver hisprize and topay his back salaries and separation benefits.
Petitioner moved to dismiss the complaint ongrounds of lack of jurisdiction.

Respondent Tumala maintains that the controversy is triable exclusively by

the court of general jurisdiction
Issue:
WON the court of general jurisdiction and not the Labor Arbiter that has
exclusive jurisdiction over the recovery of unpaid salaries,separation and
damages
Held:
NO
SC ruled that the Labor Arbiter has exclusive jurisdiction over the case.
Jurisdiction over the subjectmatter is conferred by the sovereign authority
whichorganizes the court; and it is given by law. Jurisdiction is never
presumed; it must beconferred by law in words that do not admit of doubt.
Under the Labor Code, the NLRC has the exclusive jurisdiction over claims,
money or otherwise, arisingfrom ER-EE relations, except those expressly
excludedtherefrom. The claim for the said prize unquestionablearose from an
ER-EE relation and, therefore, fallswithin the coverage of P.D. 1691, which
speaks of allclaims arising from ER-EE relations, unless expresslyexcluded by
this Code. To hold that Tumalas claim forthe prize should be passed upon by
the regular courtsof justice would be to sanction split jurisdiction
andmultiplicity of suits which are prejudicial to the orderlyof administration of
justice.
WHEREFORE, PETITION IS GRANTED.
DY vs. NLRC
Facts:
Private Respondent Carlito H. Vailoces was themanager of the Rural Bank of
Ayungon. He was also a director and stockholder of the bank. In 1983, a
special stockholders meeting was
called for the purpose of electing the members of the banks Board of
Directors. Petitioner Lorenzo Dy was elected president. Vailoces was not reelected as bank manager. Vailoces filed a complaint for illegal dismissal and
damages against Dy asserting that after obtaining control of the majority
stock of the bank, called an illegal stockholders meeting and elected a Board
of Directors controlled by him; and that he was illegally dismissed as
manager, without giving him the opportunity to be heard first. Dy denied the
charge and pointed out that Vailoces position was an electiveone, and he
was not re-elected as bank manager because of the Boards loss of
confidence in himbrought about by his absenteeism and negligence in the
performance of his duties. The Executive Labor Arbiter ruled thatVailoces was
illegally dismissed because he wasnot afforded due process of law. NLRC
affirmed the decision of the Labor Arbiter because of theappeal of the
petitioners was filed late.
Issue:
Whether the election of the Directors were validly held.
HELD: YES
Under PD No. 902-A, Controversies in the election orappointments of
directors, trustees, officers ormanagers of such corporations, partnerships
orassociations, are explicitly declared to be within theoriginal and exclusive
jurisdiction of the Securities andExchange Commission. In the CAB, it shows

that the controversy between theparties is intra-corporate in nature because

it revolvesaround the election of directors, officers or managersof the Rural
Bank of Ayungon, the relation betweenand among its stockholders, and
between them andthe corporation. It is well settled that the decision of
atribunal not vested with appropriate jurisdiction is nulland void.Therefore,
the judgment of the Labor Arbiter and theNLRC are void for lack of
jurisdiction.
WHEREFORE, PETITION IS GRANTED
SMC vs. NLRC
Facts:
Petitioner sponsored an Innovation Program which grant cash rewards to all
SMC employees who submit to the corporation ideas and suggestions found
tobeneficial to the corporation. Private Respondent Rustico Vega, who is a
mechanic of SMC submitted an innovation proposal which supposedto
eliminate certain defects in the quality and tasteof the product San Miguel
Beer Grande. Petitioner Corporation did not accept the said proposal and
refused Mr. Vegas subsequent demands for cash award. Hence, Vega filed a
complaint .He argued that his proposal had been accepted bythe methods
analyst and was implemented by theSMC and it finally solved the problem of
theCorporation. Petitioner denied of having approved Vegasproposal. It
stated that said proposal was turneddown for lack of originality and could
not achieve the desire result.Further, petitioner Corporation alleged that the
LA had no jurisdiction.The LA dismissed the complaint forlack of jurisdiction
because the claim of Vega is not a necessary incident of his employment
and does not fall under Article 217 of the Labor Code. However the Labor
Arbiter ordered petitioner to pay Vega
P2,000 as financial assistance. Both parties assailed said decision of the
Labor Arbiter. The NLRC set aside the decision of the Labor Arbiterand
ordered SMC to pay complainant the amountof P60,000
Issue:
Whether the Labor Arbiter and the Commission has jurisdiction over the
money claim filed by private respondent
HELD: NO
The court ruled that the money claim of private respondent arose out of or in
connection with his employment with petitioner. However, it is not enough to
bring Vegas money claim within the original and exclusive jurisdiction of LA.
In the CAB, the undertaking of petitioner SMC to grantcash awards to
employees could ripen into an enforceable contractual obligation on the part
of petitioner SMC under certain circumstances. Hence,the issue whether an
enforceable contract had arisen between SMC and Vega, and whether it has
been breached, are legal questions that labor legislations cannot resolved
because its recourse is the law on
contracts.Where the claim is to be resolved not by reference tothe Labor
Code or other labor relations statute or acollective bargaining agreement BUT
by the general civil law, the jurisdiction over the dispute belongs tothe
regular courts of justice and not to the LaborArbiter and NLRC.
WHEREFORE, PETITION IS GRANTED