Case Digest (G.R. No. 209011)
Facts:
Malayan Insurance Company, Inc. v. Diana P. Alibudbud, G.R. No. 209011, April 20, 2016, Supreme Court Third Division, Reyes, J., writing for the Court.
Malayan Insurance Company, Inc. (Malayan) employed Diana P. Alibudbud on July 5, 2004 as Senior Vice President for Sales and issued her a 2004 Honda Civic under its Car Financing Plan. The plan required the employee to remain in service for three years and provided that if the employee resigned, retired or was terminated before that period she must pay Malayan’s 50% equity share and any outstanding loan balance. Alibudbud signed a Promissory Note for a P360,000 loan payable over 60 months and a Deed of Chattel Mortgage securing the vehicle; these instruments spelled out immediate acceleration of unpaid balances upon separation, authorization to apply company payments to outstanding obligations, interest, penalties, foreclosure rights, return of possession upon default, and attorney’s fees if suit became necessary.
Alibudbud was dismissed for redundancy on July 18, 2005. Malayan demanded return of the vehicle; she refused. On September 21, 2005 Malayan filed a Complaint for replevin and/or sum of money before the Regional Trial Court (RTC) of Manila, Branch 27 (Civil Case No. 05-113528), seeking seizure of the car or payment of the unpaid obligation including charges and attorney’s fees. On October 12, 2005 Alibudbud filed a complaint for illegal dismissal with the Labor Arbiter (LA), seeking reinstatement.
In her RTC answer, Alibudbud asserted depreciation to reduce liability and counterclaimed for damages and attorney’s fees, moving repeatedly for suspension of the civil proceedings on the ground that the labor case presented a prejudicial question. The RTC denied suspension (Order, Feb. 17, 2006) and later denied her motion to dismiss as to the bond (Order, Oct. 5, 2006; denial of reconsideration, Dec. 19, 2006). The court found the civil action’s cause of action to be rooted in the Promissory Note and Deed of Chattel Mortgage and thus separable from the labor dispute; trial proceeded. Malayan secured an ex parte writ of preliminary attachment (June 8, 2007) and the vehicle was attached.
The LA dismissed Alibudbud’s illegal dismissal complaint on February 19, 2008, finding the redundancy valid as a management prerogative. On November 28, 2008, the RTC rendered judgment granting Malayan’s replevin action (converted into a money claim due to Alibudbud’s refusal to surrender the car), holding she remained obligated under the promissory note and mortgage.
Malayan appealed. The Court of Appeals (CA), in a Decision penned by Associate Justice Danton Q. Bueser (with Justices Amelita G. Tolentino and Ramon R. Garcia concurring) dated May 15, 2013, reversed and dismissed the RTC action for lack of jurisdiction, reasoning that Alibudbud’s rights under the Car Financing Plan were necessarily and intimately connected with her employment and thus subject to labor jurisdiction; it invoked Section 1, Rule 9 of the 1997 Rules of Court and held lack of jurisdiction may be raised at any stage. The CA denied Malayan’s ...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly dismiss the RTC action for replevin for lack of jurisdiction because the transaction giving rise to the dispute was connected to the employer-employee relationship?
- Was the RTC proper in exercising jurisdiction over the replevin/money claim given the parties’ employment relationship and the pendency (and later disposi...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)