Case Digest (G.R. No. 101767)
Facts:
The case involves Tertuliano Abejaron as the petitioner and Pepsi Cola Bottling Co., Inc. as the respondent. In 1978, Abejaron was employed by Pepsi as a salesman. In May 1980, he was suspended without pay due to an alleged failure to remit collections amounting to P67,945.70. Following this, a complaint for estafa was filed against him with the Provincial Fiscal of General Santos, which was later dismissed for lack of evidence. Abejaron was reinstated on November 11, 1980, but in November 1982, he received a warning regarding a second charge related to questionable route shortages and failure to remit daily collections. He was subsequently "grounded" pending investigation. In 1983, another estafa complaint was filed against him, leading to a trial in the Regional Trial Court of General Santos City, where he was acquitted on August 29, 1986. Despite his acquittal, Abejaron was separated from Pepsi on March 21, 1983. He did not file any complaints with the Labor Depa...
Case Digest (G.R. No. 101767)
Facts:
Employment and Suspension:
- In 1978, Tertuliano Abejaron was employed by Pepsi Cola Bottling Co., Inc. as a salesman.
- In May 1980, Pepsi suspended Abejaron without pay, alleging unremitted collections amounting to P67,945.70.
- A criminal complaint for estafa was filed against Abejaron with the Provincial Fiscal of General Santos, but it was dismissed for lack of sufficient evidence.
- Abejaron was reinstated on November 11, 1980.
Second Charge and Dismissal:
- In November 1982, Abejaron was warned about questionable route shortages and failure to remit daily collections. He was "grounded" pending investigation.
- In 1983, Pepsi filed another estafa complaint against Abejaron with the City Fiscal of General Santos City. The case was docketed as Criminal Case No. 3067.
- On August 29, 1986, Abejaron was acquitted of the estafa charge.
- Despite the acquittal, Abejaron was dismissed by Pepsi on March 21, 1983.
Civil Case for Damages:
- Abejaron did not file any complaint with the Labor Department regarding his suspension or dismissal.
- Instead, on November 24, 1986, he filed a civil case for damages against Pepsi, alleging malicious prosecution. The case was docketed as Civil Case No. 3475 in the Regional Trial Court (RTC) of General Santos City.
- On April 25, 1989, the RTC ruled in favor of Abejaron, awarding him P50,000 as actual damages, P65,317.87 as compensatory damages, P35,000 as attorney's fees, P200,000 as moral damages, and litigation expenses.
Appeal to the Court of Appeals:
- Pepsi appealed to the Court of Appeals, raising the sole issue of lack of jurisdiction by the RTC. Pepsi argued that the case was a monetary claim arising from an employer-employee relationship, which should have been under the jurisdiction of the Labor Arbiter.
- The Court of Appeals rejected Pepsi's argument, holding that the case was based on malicious prosecution, not illegal termination, and thus fell under the jurisdiction of the RTC.
Issue:
- Whether the Regional Trial Court had jurisdiction over Abejaron's complaint for damages, given that the claim arose from an employer-employee relationship.
- Whether the Court of Appeals erred in modifying the award of damages despite the issue not being assigned as an error by Pepsi.
Ruling:
- Jurisdiction: The Supreme Court affirmed the Court of Appeals' ruling that the RTC had jurisdiction over Abejaron's complaint. The Court held that the complaint was based on malicious prosecution, not illegal termination, and thus was a civil dispute cognizable by the regular courts.
- Award of Damages: The Supreme Court upheld the Court of Appeals' decision to modify the award of damages. The Court found that there was no convincing evidence of malice on Pepsi's part in filing the estafa charge against Abejaron. Therefore, Abejaron was not entitled to damages.
Ratio:
- (Unlock)