TUMAODOS v. SAN MIGUEL YAMAMURA

G.R. No.
241865 | Feb 19, 2020

TRIFON B. TUMAODOS v. SAN MIGUEL YAMAMURA PACKAGING CORP
Inting, J.:
FACTS:
Petitioner Tumaodos was an employee of respondent San Miguel Yamamura Packaging Corporation.
Tumaodos availed of the Involuntary Separation Program implemented by respondent due to its plant
reorganization.
Respondent paid out petitioner's separation benefits, less the amount withheld. Petitioner signed a Receipt
and Release in favor of respondent, but he made a notation that the amount of P1,400,000.00 was still subject to
verification. Respondent later received a letter from petitioner wherein he claimed that he no longer had any
outstanding obligation to the Cooperative. Thus, petitioner demanded respondent to release to him the withheld
amount.Respondent also received a letter from the Cooperative, disputing petitioner's assertions and also claiming
entitlement to the withheld amount.
Petitioner filed a complaint before the NLRC Regional Arbitration Branch No. VII for nonpayment of
separation pay and damages.
The Labor Arbiter ordered the respondent to pay Tumaodos refund of excess deductions, separation pay
withheld and damages. The National Labor Relations Commission affirmed the ruling of the Labor Arbiter.
The CA nullified and set aside the decision of the NLRC. The CA ruled that the issues raised and the reliefs
prayed for by petitioner in his position paper are not cognizable by the labor tribunals. Hence, this petition.
ISSUE/S:
1. What is the extent of the jurisdiction of the LA over money claims and damages
2. Reasonable casual connection rule
RULING:
In cases involving workers and their employers, the delineation between the jurisdiction of the regular
courts and that of the labor courts has always been a matter of dispute. In this case, the Court agrees with the CA
that it is the regular courts that have jurisdiction over petitioner's claims. Not all controversies or money claims by
an employee against the employer or vice versa fall within the exclusive jurisdiction of the LA. With regard to
money claims and damages, Article 224 (formerly Article 217) of the Labor Code, as amended, bestows upon the
LA original and exclusive jurisdiction over cases filed by workers involving wages, among others, if accompanied by
a claim for reinstatement; all claims, except those for Employees Compensation, Social Security, Medicare and
maternity benefits, arising from employer-employee relations involving an amount exceeding P5,000.00
regardless of whether accompanied with a claim for reinstatement; and claims for actual, moral, exemplary and
other forms of damages arising from employer-¬employee relations. As can be gleaned above, the jurisdiction of
the LA over money claims and damages is confined to those cases which are either accompanied by a claim for
reinstatement or arising from employer-employee relations. Here, the Court finds that petitioner's claims do not
fall under any of these cases.
For the 2nd issue, in ruling that the determination of the case is beyond the competence of the labor tribunals, the
CA found that although employment relations existed between respondent and petitioner, and the subject of the
complaint before the LA was petitioner's money claims against respondent, such money claims did not involve and
did not arise out of such employment relationship. Hence, the CA held that the jurisdiction over petitioner's claims
belonged to the RTC, and not the labor tribunals. The Court agrees. In Indophil Textile Mills, Inc. v. Engr. Adviento
(G.R. No. 171212, August 20, 2014) , the Court declared: “While we have upheld the present trend to refer worker
employer controversies to labor courts in light of the aforequoted provision, we have also recognized that not all
claims involving employees can be resolved solely by our labor courts, specifically when the law provides
otherwise. For this reason, we have formulated the "reasonable causal connection rule," wherein if there is a
reasonable causal connection between the claim asserted and the employer-employee relations, then the case is
within the jurisdiction of the labor courts; and in the absence thereof, it is the regular courts that have jurisdiction.
Such distinction is apt since it cannot be presumed that money claims of workers which do not arise out of or in
connection with their employer-employee relationship. and which would therefore fall within the general
jurisdiction of the regular courts of justice, were intended by the legislative authority to be taken away from the
jurisdiction of the courts and lodged with Labor Arbiters on an exclusive basis.”
To the Court, petitioner's claims have no "reasonable causal connection" with his employment relationship with
respondent. It bears to point out that the case that petitioner filed was neither a complaint for illegal dismissal nor
a claim for reinstatement. His complaint was for alleged nonpayment of separation benefits and damages. It is
notable, however, that respondent never denied petitioner's entitlement to his separation pay. In fact, respondent
paid out petitioner's separation package, except that it withheld the amount which, purportedly, was his
outstanding indebtedness to the Cooperative. Petitioner, in turn, signed a Receipt and Release in favor of
respondent but made notation that the amount withheld was still subject to verification.
It appears, thus, that the principal relief sought by petitioner in his complaint was not the payment of his separation
package but the release to him of the withheld amount, to which both he and the Cooperative claimed entitlement.
In addition, he also sought the return of the alleged excess deductions. Ergo, given that the disputed withheld
amount and the alleged excess deductions both relate to petitioner's alleged indebtedness to the Cooperative and
not to respondent, it becomes apparent that the controversy involves debtor-creditor relations between petitioner
and the Cooperative, rather than employer-employee relations between respondent and petitioner. Evidently, the
employer¬-employee relationship between respondent and petitioner in this case is merely incidental and the
principal relief sought by petitioner can be resolved not by reference to the Labor Code or other labor relations
statute or a collective bargaining agreement but by the general civil law.

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G.R. No.

241865 | Feb 19, 2020

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