Case Digest (G.R. No. 154830)
Case Digest (G.R. No. 154830)
Facts:
Pioneer Concrete Philippines, Inc., Pioneer Philippines Holdings, and Philip J. Klepzig, G.R. No. 154830, June 08, 2007, the Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.On January 16, 1998, Antonio D. Todaro filed with the Regional Trial Court (RTC) of Makati City a complaint for sum of money and damages with preliminary attachment against Pioneer International Limited (PIL), Pioneer Concrete Philippines, Inc. (PCPI), Pioneer Philippines Holdings, Inc. (PPHI), John G. McDonald, and Philip J. Klepzig. Todaro alleged that PIL (an Australian corporation) had negotiated with him to engage his services first as a short‑term consultant and thereafter to employ him as manager of its ready‑mix concrete operations in the Philippines, but later reneged on its undertaking to employ him on a permanent basis; he sought damages and relied alternatively on Articles 19 and 21 of the Civil Code.
Instead of answering, PPHI, PCPI and Klepzig separately moved to dismiss the complaint on grounds that it stated no cause of action, that the RTC lacked jurisdiction because the case fell within the exclusive competence of the National Labor Relations Commission (NLRC), and on the basis of the doctrine of forum non conveniens. The RTC, Branch 147, denied the motions to dismiss in its Order dated January 4, 1999, and likewise denied an Omnibus Motion for Reconsideration in its Order of June 3, 1999.
Petitioners elevated the matter to the Court of Appeals (CA) by filing a petition for certiorari on August 3, 1999 (CA‑G.R. SP No. 54155). The CA, in a Decision dated October 31, 2000 (penned by Justice Oswaldo D. Agcaoili), denied the petition; its Resolution of August 21, 2002 denied petitioners’ motion for reconsideration. Petitioners then filed this Petition for Review on Certiorari with the Supreme Court seeking annulment of the CA decision and resolution, advancing three principal assignments of error: (A) the complaint states no cause of action because the annexes show no perfected employment contract; (B) the RTC lacked jurisdiction because the dispute falls within the exclusive jurisdiction of the NLRC as an employment‑contract matter; and (C) the case should have been dismissed under the doctrine of forum non conveniens.
Issues:
- Does the complaint as pleaded and annexed state a cause of action cognizable by the RTC?
- Is the RTC devoid of jurisdiction because the dispute falls within the exclusive jurisdiction of the NLRC?
- Should the complaint have been dismissed on the ground of forum non conveniens?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)