Title
Nestle Philippines, Inc. vs. National Labor Relations Commission
Case
G.R. No. 85197
Decision Date
Mar 18, 1991
A dispute between Nestle Philippines, Inc. and its employees regarding car loan payments is deemed a civil matter, not a labor dispute, by the Supreme Court, leading to the annulment of the National Labor Relations Commission's resolution.
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Case Digest (G.R. No. 85197)

Facts:

  • Parties Involved: Nestle Philippines, Inc. vs. National Labor Relations Commission (NLRC) and former employees Eugenia C. Nuez, Liza T. Villanueva, Emmanuel S. Villena, Rudolph C. Armas, Rodolfo M. Kua, and Rodolfo A. Solidum.
  • Date of Decision: March 18, 1991.
  • Context: The dispute arose from Nestle’s car loan policy, where the company advanced money for employees to purchase cars, repaid through salary deductions.
  • Employee Dismissals: Nuez, Villanueva, Villena, and Armas were dismissed for participating in an illegal strike on September 14, 1987. Kua and Solidum were dismissed on December 26, 1987, for other irregularities.
  • Complaints Filed: The dismissed employees filed illegal dismissal complaints with the NLRC.
  • NLRC Involvement: NLRC issued an injunction to stop Nestle from canceling the car loans and collecting payments until the resolution of the illegal dismissal cases.
  • Nestle’s Action: Nestle filed a civil suit in the Regional Trial Court of Makati, which ordered the seizure of the cars.
  • Petition for Certiorari: Nestle argued that the NLRC acted with grave abuse of discretion.

Issue:

  • (Unlock)

Ruling:

  • Grave Abuse of Discretion: The Supreme Court ruled that the NLRC acted with grave abuse of discretion and exceeded its jurisdiction by issuing the writ of injunction.
  • Nature of Dispute: The Supreme Cou...(Unlock)

Ratio:

  • Interpretation of Labor Code: The Supreme Court based its decision on the interpretation of the Labor Code.
  • Article 218: Grants the NLRC power to issue writs of injunction only in the context of labor disputes.
  • Article 212: Defines labor disputes as controversies concerning employment terms or representation.
  • Nature of Dispute: The Court found that the dispute was a civil matter involving debtor-creditor relations, not employee-employer relations.
  • Contractual Obligations: The car loan agreeme...continue reading

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