Case Digest (G.R. No. 88705)
Facts:
This case involves Manuel L. Garcia as the petitioner and the Court of First Instance of Davao, Judge Antonio M. Martinez, and Jose Velasco, Jr. as the respondents. The events leading to the case began on August 5, 1976, when Jose Velasco, Jr. filed a complaint against Garcia and Eastern Broadcasting Corporation (EBC), alleging unlawful termination from his position as manager of radio station DXER in Davao City. Velasco claimed he was appointed station manager in March 1976, and that on July 19, 1976, Garcia informed him verbally that his services would be terminated by July 31, 1976, allegedly without justification and in violation of his right to security of tenure. He described the termination as oppressive and, following it, noted that his duties were transferred to another individual without a formal transition. Velasco asserted that he suffered damages amounting to PHP 155,000, in addition to seeking exemplary damages, attorney’s fees, and litigation costs but did not purCase Digest (G.R. No. 88705)
Facts:
- Parties and Background
- Petitioner: Manuel L. Garcia, who filed the petition for prohibition and certiorari.
- Respondents:
- Hon. Antonio M. Martinez,
- Jose Velasco, Jr., and
- Eastern Broadcasting Corporation.
- Nature of the Case:
- The case involves a prohibition and certiorari petition challenging the order of the Court of First Instance of Davao (Davao City Branch VI).
- Garcia contends that the lower court lacks jurisdiction over the action for damages brought by Velasco, a dismissed employee.
- Filing and Alleged Claims
- Velasco’s Complaint:
- Filed on August 5, 1976 in Civil Case No. 9657, where Velasco alleged that:
- He was appointed manager of radio station DXER in Davao City in March 1976.
- He also claimed exemplary damages, attorney’s fees, and litigation expenses, but did not request reinstatement or back salaries.
- Motions to Dismiss:
- On October 28, 1976, Garcia, along with Eastern Broadcasting Corporation, filed motions to dismiss the complaint on grounds of:
- Lack of jurisdiction,
- Lower Court Ruling:
- The Court of First Instance denied the motions to dismiss in its order dated February 10, 1977.
- Garcia subsequently filed the petition for prohibition on January 13, 1978, contesting the lower court’s order.
- Jurisdictional Conflict and Prior Precedents
- Garcia and Eastern Broadcasting Corporation’s Position:
- They argue that the lower court has no jurisdiction over claims for damages arising from employee-employer relations.
- They contend that such cases should be filed with the National Labor Relations Commission (NLRC) or handled by the Labor Arbiters.
- Velasco’s Reliance:
- Velasco supports his claim by invoking Article 21 of the Civil Code and the precedent established in Quisaba vs. Sta. Ines-Melale Veneer & Plywood, Inc.
- He asserts that the lower court retains exclusive original jurisdiction over his claim for damages.
- Relevant Legal Provisions and Comparative Cases:
- Article 217 of the Labor Code is central, outlining the exclusive jurisdiction of the Labor Arbiters and the NLRC in matters involving employee-employer relations.
- The case was compared to previous decisions such as Quisaba and Ruby Industrial Corporation vs. Court of First Instance of Manila to delineate the proper forum for claims based on the termination’s “manner” and its effects.
Issues:
- Jurisdiction
- Whether the Court of First Instance has subject-matter jurisdiction over Velasco’s claim for damages, or whether the case falls exclusively within the administrative jurisdiction of the Labor Arbiters and the NLRC.
- Applicable Legal Framework
- Whether the broad provisions of Article 217 of the Labor Code, particularly paragraphs 3 and 5, adequately confer exclusive jurisdiction on labor tribunals to hear claims for damages resulting from termination.
- Precedential Distinctions
- Whether the earlier ruling in Quisaba, which dealt with a similar dismissal situation, is applicable to the present case under the changed jurisdictional framework provided by the current NLRC and Labor Arbiters.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)