Title
Aguda vs. Vallejos
Case
G.R. No. 58133
Decision Date
Mar 26, 1982
Seven canteen employees dismissed in 1980 filed labor and civil cases; Supreme Court ruled damages claims fall under labor jurisdiction, affirming dismissal of civil suit.

Case Digest (G.R. No. 58133)

Facts:

Mercedes Aguda et al. v. Judge Amador T. Vallejos and Adamson Ozanam Educational Institution, Inc., G.R. No. 58133, March 26, 1982, Supreme Court Second Division, Aquino, J., writing for the Court.

The seven petitioners (former canteen employees of Adamson Ozanam Educational Institution, Inc.) worked for the school from 1974 until their abrupt dismissal on June 2, 1980. On June 27, 1980 they filed an administrative complaint with the National Capital Region office of the Ministry of Labor (docketed NCR-S11 63655'80 or No. AB-7-7490-80), alleging illegal dismissal and claims for underpayment, overtime, holiday and premium pay, and violations of several Presidential Decrees (PD Nos. 525, 1123, 928 and 1389); that administrative case remained pending.

Separately, on July 2, 1980 the petitioners instituted a civil action in the Court of First Instance of Manila (Civil Case No. 133008) seeking recovery of actual, moral and exemplary damages in the aggregate amount of P300,000 against Adamson Ozanam Educational Institution, Inc. Respondent Judge Amador T. Vallejos, Branch XXII, granted the institution’s motion to dismiss by order dated July 22, 1980, holding that the claim for damages fell exclusively within the jurisdiction of the Bureau of Labor Relations (the labor tribunal then exercising jurisdiction).

The petitioners moved for reconsideration; because the motion lacked notice of hearing the trial court treated it as a mere scrap of paper and reiterated dismissal in orders of September 3 and September 24, 1980. The case was later dismissed without prejudice b...(Subscriber-Only)

Issues:

  • Did the Court of First Instance err in dismissing the petitioners' civil complaint for damages on the ground that it lacked jurisdiction?
  • Do claims for actual, moral, and exemplary damages arising from dismissal of employees fall within the exclusive original jurisdiction of Labor Arbiters and the National Labor Relations Commission under Presidential Decree No. 16...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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