Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 2

GROTJAHN & CO. VS HON.

ISNANI, ET AL
FACTS:

Georg Grotjahn & Co. (multinational company organized and existing under the laws of
the Federal Republic of Germany) impugns the dismissal of its Complaint for a sum of
money by Hon. Isnani (Presiding Judge of RTC, Makati) for lack of jurisdiction and lack
of capacity to sue.

It was registered on September 1983; the Company was issued a COR by SEC and a
License by BOI for the establishment of a regional or area headquarters in the
Philippines.

Romana R. Lanchinebre was a sales representative in the company from 1983 to 1992.
1. On March 1992, secured a loan P25,000
2. On June 1992, additional cash advances P10,000

A total of P12,170.37 remained unpaid and failed to settle obligation despite demand by
the company.

On July 1992, Romana filed a complaint for illegal suspension, dismissal and non-
payment of commissions against petitioner with the NLRC in Manila.

On September 1992, the Company complaint for collection of money.

Judge Isnani granted a motion to dismiss with the case stating that:

Jurisdiction over the subject matter or nature of the action is conferred by law and not
subject to the whims and caprices of the parties.

Under Article 217 of the Labor Code, the Labor Arbiters shall have original and
exclusive jurisdiction to hear and decide, within thirty (30) calendar days after the
submission of the case by the parties for decision, to:

(4) claims for actual, moral, exemplary and other forms of damages arising from an
employer-employee relation.

In this case, the company seeks to recover Cash Advances made by Romana while still
employed and hence made pursuant to a EE Relationship between them. As such
NLRC has original and exclusive jurisdiction.

Motion for Reconsideration was denied.

ISSUE:
Whether or not RTC erred in holding that regular courts have no jurisdiction over this
case with purely issues with General Civil Law.
RULING:
YES. RTC has jurisdiction over this case.

It is true that the collection of money sough to be recovered by the Company were
contracted by Romana while still in the employ of the later. Still does not follow that
Labor Code covers their relationship and the issue at hand.

Not all dispute between an EE involves matters that LA and NLRC can resolve in the
exercise of their adjudicatory or quasi-judicial powers.

It was held further that it is limited to disputes arising from an EE Relationship which can
only be resolve by reference of the LC, Labor Statutes or CBAs.

Medina v Castro-Bartolome >> LC not CIV


Negate jurisdiction of LA, the test if LA has jurisdiction over a case is whether or
not the LC has any relevance to the reliefs sought.

Singapore Airlines Limited v Paño [Discussed] CIV not LC


If relief sought are consequences flowing from breach of an obligation it is
intrinsically a civil dispute.

San Miguel Corp v NLRC


Bolstered the ideas in the cases mentioned that:
If principal relief sough is to be resolved not by reference with LC, labor statutes, and
CBAs, but by general civil law. The jurisdiction belongs to regular courts and not with
LA or NLRC.

CONCLUSION:

In this case, the Civil Case filed with the RTC is a simple collection of sums of money
brought by the Company as the creditor, against Romana as debtor.

The relationship is immaterial and does not negate the jurisdiction of the RTC.

Hence, the case can be resolve with our civil laws on obligation and contract and not by
our LC.

You might also like