Case Digest (G.R. No. 128024)
Facts:
Bebiano M. Banez v. Hon. Downey C. Valdevilla and Oro Marketing, Inc., G.R. No. 128024, May 09, 2000, Supreme Court Third Division, Gonzaga‑Reyes, J., writing for the Court. Petitioner Bebiano M. Banez was the sales operations manager of private respondent Oro Marketing, Inc. at its Iligan City branch. In 1993 Oro Marketing indefinitely suspended petitioner; petitioner filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC) through the Labor Arbiter. On July 7, 1994, Labor Arbiter Nicodemus G. Palangan found petitioner illegally dismissed and awarded separation pay in lieu of reinstatement, backwages, and attorney’s fees.Oro Marketing appealed to the NLRC, but the NLRC dismissed the appeal as filed out of time (NLRC resolution dated August 4, 1995; motion for reconsideration denied September 26, 1995). A petition for certiorari to the Supreme Court was dismissed on technical grounds (failure to comply with SC Circular 19‑91) by the Court’s Third Division on December 13, 1995; the Court also stated that even on the merits the petition would be dismissed for failure to show grave abuse of discretion by the NLRC.
On November 13, 1995 Oro Marketing filed a separate civil complaint for damages in the Regional Trial Court (RTC) of Misamis Oriental, Civil Case No. 95‑554, claiming P709,217.97 (plus interest) as lost profits, P119,700 (plus interest) as estimated costs, P5,000 for litigation expenses, and P25,000 as attorney’s fees. Petitioner moved to dismiss on January 30, 1996, arguing lack of subject‑matter jurisdiction—claiming exclusive original jurisdiction of Labor Arbiters/NLRC under Article 217(a), paragraph 4 of the Labor Code (as amended by R.A. No. 6715), res judicata, splitting of causes of action, and forum‑shopping.
Respondent judge of Branch 39, RTC Misamis Oriental, issued an order dated June 20, 1996 taking jurisdiction, describing the claim as a civil breach of contractual obligation and relying on Singapore Airlines, Ltd. v. Pano. The court denied petitioner’s motion for reconsideration on October 16, 1996. Petitioner filed a petition for certiorari under Rule 65 alleging grave abuse of discretion; the Second Division of the S...(Pro-only)
Issues:
- Did the Regional Trial Court have jurisdiction over Oro Marketing’s complaint for damages claimed against its former employee, or was jurisdiction exclusive to labor tribunals under Article 217(a), paragraph 4 of the Labor Code as amended by R.A. No. 6715?
- If jurisdiction was exclusive to the labor tribunals, were Oro Marketing’s claims nevertheless actionable in the RTC by reason of res judicata, splitting of ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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