G.R. No. 139762 - Radio Communications of the Philippines, Inc. vs. Court of Appeals

From 1983 to 1991, Roberto Villalon provided messenger services to Radio Communications of the Philippines, Inc. (RCPI) at its branch office in BiAan, Laguna.
The arrangement entailed payment based on the number of deliveries with the following scheme: 69% to Villalon, 30% to RCPI, and 1% allocated to taxes.

In April 1991, RCPI stopped paying Villalon pursuant to the established arrangement.
On June 26, 1991, Villalon filed a complaint for the collection of money against RCPI with the Regional Trial Court (RTC) of BiAan, Laguna (Civil Case No. B-3574).

RCPI moved to dismiss the complaint on the ground that the subject matter involved a money claim arising from an employer-employee relationship, a matter allegedly falling under the jurisdiction of the labor arbiter.
The RTC denied the motion to dismiss, ruling that:

Villalon was a “contractual messenger” rather than an employee.
There was no agreement regarding wages or a fixed duration of work.
RCPI did not control the means by which Villalon performed his deliveries and compensated him based solely on the results of his work.

The trial court declared RCPI in default because its motion to dismiss did not include a notice of hearing, causing RCPI to miss the reglementary period for filing a responsive pleading.
On March 6, 1992, the RTC rendered its decision awarding Villalon P67,979.77 as unpaid wages/commission with 12% interest until full payment, plus costs.

RCPI filed a motion for reconsideration, which was denied in a resolution dated November 15, 1991.
On December 13, 1991, RCPI initiated a petition for certiorari, prohibition, and mandamus (G.R. No. 102959), alleging grave abuse of discretion on the denial of its motion to dismiss.
In a resolution dated February 28, 1994, the petition was dismissed, with the Court remanding the case for further proceedings on the ground that the trial court had correctly assumed jurisdiction by ruling that Villalon was not in an employer-employee relationship.

RCPI appealed the RTC decision to the Court of Appeals, which subsequently dismissed the appeal in its May 10, 1999 decision.
RCPI then raised two primary issues in its petition:

Whether the RTC had jurisdiction over the complaint given the argument that the relationship was that of employer-employee, thereby belonging to the labor arbiter’s jurisdiction.
Whether the imposition of a 12% per annum interest rate was correct, in view of the contention that a lower rate of 6% per annum should apply to a breach of contract involving services.

The Court reaffirmed the trial court’s jurisdiction by emphasizing that Villalon was a contractual messenger remunerated by the number of deliveries made.
The court established that under the law of the case doctrine, the issue of jurisdiction had been conclusively decided in the earlier petition (G.R. No. 102959) and could not be re-litigated.
Regarding the interest rate, the court found that the appropriate rule for breaches of service contracts was to impose an interest rate of 6% per annum from the date of the RTC decision, shifting to 12% per annum only after the judgment became final and executory if still unsatisfied.
Ultimately, the Court of Appeals’ decision was affirmed with the noted modification in the computation of interest.

Whether the RTC had jurisdiction over the complaint, considering RCPI’s claim that the dispute involved an employer-employee relationship subject to the exclusive jurisdiction of the labor arbiter.
The issue also involved whether reasserting this jurisdictional argument was barred by the law of the case doctrine.

Whether the imposition of a 12% per annum interest rate was erroneous.
Whether, on a breach of contract for services (as opposed to a monetary loan or forbearance), a 6% per annum interest rate was the proper measure.

Whether RCPI could reopen the issue on jurisdiction already resolved in its earlier petition (G.R. No. 102959) despite its reappearance in the current petition.