LABOR LAW

Eduardo Eviota v. CA et al.

GR 152121, July 29, 2003

FACTS:
Sometime on 1/26/1998 Standard Chartered Bank employed Eviota as Compensation and Benefits
Manager. However, petitioner resigned from respondent bank after barely a month later and rejoined his
former employer. On 6/19/1998 respondent bank filed a complaint with RTC Makati City citing as its first
cause of action Eviota's violation of Arts. 19, 20, 21 of RA 386 (NCC) for improper termination of contract
and by his actions and representations led the respondent bank to incur expenses totaling PHP
1,272,636 and actual damages of PHP 360,562.12.

Second cause cited by respondent bank is Eviota's violation of Art. 285 (a) of PD 442 as amended by
failing to provide at least a 1 month notice to the employer before terminating without just cause an
employment. Eviota's failure to comply with said provision resulted in chaos in the bank's scheduled
meetings. Eviota is then liable for damages in the amount of PHP 100K. Third cause of action is Eviota's
false and derogatory statements that respondent bank does not treat its employees properly, damaging
the banks reputation. Exemplary damages accrue to the bank in the amount of PHP 1M, attorney's fees
of PHP 200K.

Petitioner filed a motion to dismiss citing lack of jurisdiction of the RTC of Makati City the same being with
the LA under par. 4, Art. 217 of LC. On 11/29/1999 trial court denied petitioner's motion to dismiss. Motion
for Reconsideration of petitioners was denied by court a quo. On appeal with CA, the same was denied.

ISSUE:

Is the plaintiffs complaint within the jurisdiction of the LA?

RULING:

No, the nature of the action and the subject matter thereof, as well as which court has jurisdiction
over the same, are determined by the material allegations of the complaint and the reliefs prayed for in
relation to the law provided. A money claim by a worker or vice versa is within the exclusive jurisdiction of
the LA only if there is a "reasonable causal connection" between the claim asserted and employer-
employee relation. Absent such link, the complaint will be cognizable by the regular courts of justice.

In Georg Gratjahn GMBH and Co. v. Isnani, the court held that the jurisdiction of the LA under Art. 217 of
LC, as amended, is limited to disputes arising from an employer-employee relationship which can only be
resolved by reference to the LC, other labor laws or their CBA. In Singapore Airlines v. Pao, the
complaints of the employer against the employee for damages for wanton justice and refusal without just
cause to report for duty and for having maliciously and with bad faith violated the terms and conditions of
their agreement for a course of conversion training and the expense of the employer, such jurisdiction
belongs to the civil court.

Actions for breach of contractual obligations is essentially a civil dispute and belongs to the civil courts.
While the cause of action seemingly arose from an employer-employee relations, the employer claim for
damages is grounded on "wanton failure and refusal" without just cause to report to duty coupled with the
averment that the employee "maliciously and with bad faith" violated the terms and conditions of the
contract. Such is removed from the coverage of the LC and within the purview of the Civil Law.

Petition DENIED. CA ruling is affirmed.