Case Digest (G.R. No. 64673)
Facts:
The case involves A. Consteel Construction Company, Incorporated as the petitioner and the Intermediate Appellate Court, along with private respondents Danilo C. Reyes, Felixberto Macaspac, Jaime C. Paule, Rogelio De Jesus, Delfin Nuqui, Vicente Flores, Godofredo D. Banal, Manuel Guevarra, and Enrique Manansala. The events leading to the case began on October 23, 1980, when the private respondents filed a complaint for Breach of Contract with Damages against the petitioner in the Court of First Instance of Pampanga, Fifth Judicial District, which was docketed as Civil Case No. 5913. The private respondents alleged that they were hired by the petitioner in 1978 to work on construction projects in Saudi Arabia. Prior to their departure, they signed employment contracts outlining the terms and conditions of their employment. However, while working in Saudi Arabia, the private respondents claimed they were not compensated adequately, nor did they receive overtime or holiday pay, ...
Case Digest (G.R. No. 64673)
Facts:
Employment Contracts and Allegations:
In 1978, private respondents (Danilo C. Reyes et al.) were hired by petitioner A. Consteel Construction Company, Inc. to work on construction projects in Saudi Arabia. Employment contracts were signed in the Philippines outlining the terms and conditions of their employment.
Breach of Contract Claims:
While working in Saudi Arabia, private respondents alleged that they were not provided adequate compensation, overtime/holiday pay, medical benefits, or adequate meals. They filed a complaint for Breach of Contract with Damages before the Court of First Instance of Pampanga on October 23, 1980, seeking payment for the difference between the agreed compensation and what they actually received, as well as moral and exemplary damages.
Jurisdictional Dispute:
Petitioner moved to dismiss the case, arguing that jurisdiction over the matter belonged to the Bureau of Employment Services under Presidential Decree No. 1412, which amended Article 15(b) of the Labor Code. Private respondents opposed, asserting that the Court of First Instance had jurisdiction since their claims were not purely monetary but also involved damages not capable of pecuniary estimation.
Lower Court Ruling:
The trial court denied petitioner’s motion to dismiss, and the Court of Appeals affirmed, holding that the court a quo had jurisdiction because the claims involved unpaid salaries and damages resulting from alleged breach of contract.
Issue:
The primary issue is whether the Court of First Instance has jurisdiction over claims for damages arising from an overseas employment contract, or if such jurisdiction lies with the Bureau of Employment Services (and later, the Philippine Overseas Employment Administration) under special labor laws.
Ruling:
The Supreme Court ruled in favor of the petitioner. It held that the Court of First Instance lacked jurisdiction over the case. The claims of private respondents, although framed as damages, were essentially money claims arising from employer-employee relations involving overseas employment. Such claims fall under the exclusive jurisdiction of the Bureau of Employment Services (and later, the Philippine Overseas Employment Administration) as provided under Presidential Decree No. 1412 and subsequent laws.
The Court directed the dismissal of Civil Case No. 5913.
Ratio:
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