G.R. No. 89621 - Pepsi Cola Distributors of the Philippines, Inc. vs. Gal-lang

The private respondents were employees of Pepsi Cola Distributors of the Philippines, Inc.
They were suspected of being involved in the irregular disposition of empty Pepsi Cola bottles.
The suspicion led the petitioners to initiate criminal proceedings.

On July 16, 1987, the petitioners filed a criminal complaint for theft against the private respondents.
The initial complaint was later withdrawn and substituted with a complaint for falsification of private documents.
A preliminary investigation was conducted by the Municipal Trial Court of Tanauan, Leyte.
The criminal complaint was dismissed on November 26, 1987.
The dismissal was later affirmed on April 8, 1988, by the Office of the Provincial Prosecutor.

Following an administrative investigation, the petitioner company dismissed the private respondents on November 23, 1987.
The dismissed employees subsequently lodged a complaint for illegal dismissal with the Regional Arbitration Branch of the NLRC in Tacloban City on December 1, 1987, demanding their reinstatement and damages.
Additionally, on April 4, 1988, they filed a separate civil complaint in the Regional Trial Court of Leyte, seeking damages for alleged malicious prosecution.
The petitioners moved to dismiss the civil complaint on the ground that it involved employee-employer relations exclusively within the labor arbiter’s jurisdiction under Article 217 of the Labor Code.
The motion to dismiss was initially granted on February 6, 1989, but was later reinstated on July 6, 1989, by the respondent judge acting on a motion for reconsideration.

The petitioners relied on Article 217 of the Labor Code along with several judicial decisions to argue that the civil complaint for damages should fall under the exclusive jurisdiction of the labor arbiter.
They cited cases such as Getz Corporation v. Court of Appeals, contending that matters arising from employee-employer relations must be handled by the labor courts.

The employees’ claim centered on allegations that the petitioners acted with bad faith by proceeding with a criminal complaint intended to harass them.
They argued that the malicious prosecution was not connected to any legitimate employment concerns, since no unfair labor practice was alleged.
It was noted that the criminal complaint had been dismissed for lack of evidence sufficient to establish any probability of the employees’ complicity.

Whether the civil complaint for damages for malicious prosecution, filed by the dismissed employees, falls under the exclusive jurisdiction of the labor arbiter pursuant to Article 217 of the Labor Code.
Whether the nature of the claim, involving alleged malicious prosecution, is inherently tied to employee-employer relations or is a distinct civil matter governed by general civil law.

Whether the claim should be resolved under the labor law regime (and thus within the ambit of exclusive jurisdiction of labor arbiter and NLRC) or under the general civil law.
Whether there exists a reasonable causal connection between the alleged malicious prosecution and the employment relationship.

How previous decisions (e.g., Getz Corporation v. Court of Appeals, Medina v. Castro-Bartolome, Singapore Airlines Ltd. v. Pano, and Molave Motor Sales, Inc. v. Laron) guide the current issue on jurisdiction.
Whether changes in Article 217 following R.A. 6715 have a bearing on the present dispute.