Case Digest (G.R. No. 178055)
Facts:
Amecos Innovations, Inc. and Antonio F. Mateo sued Eliza R. Lopez in the Metropolitan Trial Court, alleging she misrepresented her employment status which led them to pay P27,791.65 to the Social Security System (SSS) and seeking damages; the MeTC dismissed the complaint for lack of jurisdiction. The Regional Trial Court and the Court of Appeals affirmed, holding that the dispute arose from the employer-employee relationship and thus fell within the exclusive jurisdiction of the labor tribunals under Article 217(a)(4) of the Labor Code.Issues:
- Does the regular civil court, and not the Labor Arbiter or the National Labor Relations Commission, have jurisdiction over claims for reimbursement arising from employer-employee relations?
- Does the regular civil court, and not the Labor Arbiter or the National Labor Relations Commission, have jurisdiction over claims for damages for misrepresentation arising from employer-employee relations?
Ruling:
The Court denied the petition an Case Digest (G.R. No. 178055)
Facts:
- Parties and capacities
- Amecos Innovations, Inc. — corporation engaged in selling assorted products; petitioner.
- Antonio F. Mateo — President of Amecos and co-petitioner.
- Eliza R. Lopez — respondent; former employee of Amecos.
- Social Security System (SSS) — filed a complaint for alleged delinquent remittance of SSS contributions and penalties.
- Employment and alleged misrepresentation
- Respondent was allegedly hired by Amecos on January 15, 2001 as Marketing Assistant and was terminated in February 2002.
- Petitioners alleged that upon hiring respondent refused to divulge her SSS number, refused salary deductions for SSS, and represented that she had other employment and was self-employed.
- SSS proceedings and subsequent settlement
- On May 30, 2003, Amecos received a subpoena from the Office of the City Prosecutor of Quezon City in connection with an SSS complaint for unremitted contributions and penalties under relevant provisions of the Social Security Law.
- Amecos attributed nonremittance to respondent's alleged misrepresentations.
- Amecos eventually settled its obligations with SSS, and SSS filed a Motion to Withdraw Complaint which the City Prosecutor approved.
- Petitioners' demand and civil action
- Petitioners sent a demand letter to respondent for P27,791.65 as her share in SSS contributions and processing expenses; respondent did not pay.
- Petitioners filed a Complaint for sum of money and damages (Civil Case No. 04-27802) in the Metropolitan Trial Court (MeTC) of Caloocan City seeking P27,791.65; P50,000.00 moral damages; P50,000.00 exemplary damages; P50,000.00 attorneys’ fees; and costs.
- Respondent's answer and jurisdictional defense
- Respondent filed an Answer with Motion to Dismiss alleging illegal dismissal in February 2002 and that Amecos deliberately failed to deduct and remit SSS contributions.
- Respondent maintained that the regular courts lacked jurisdiction because the dispute arose from an employer-employee relationship and that the Complaint was retaliatory.
- Evidence bearing on remittance and coverage
- An SSS demand letter covered non-payment of contributions from January 2001 to April 2002 totaling P85,687.84.
- Amecos payroll for January 30 to November 29, 2001 showed no deductions for respondent’s SSS contributions,...(Subscriber-Only)
Issues:
- Jurisdictional question regarding reimbursement claims
- WHETHER THE REGULAR CIVIL COURT AND NOT THE LABOR ARBITER OR THE NATIONAL LABOR RELATIONS COMMISSION HAS JURISDICTION OVER CLAIM[S] FOR REIMBURSEMENT ARISING FROM EMPLOYER-EMPLOYEE RELATIONS.
- Jurisdictional question regarding damages for misrepresentation
- WHETHER THE REGULAR CIVIL COURT AND NOT THE LABOR ARBITER OR THE NA...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)