Case Digest (G.R. No. 155990)
Facts:
Universal Aquarius, Inc. and Conchita Tan, Petitioners, vs. Q.C. Human Resources Management Corporation, Respondent, G.R. No. 155990, September 12, 2007, Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.Universal Aquarius, Inc. (Universal) manufactured and distributed chemical products and operated a plant in Antipolo City. Conchita Tan, trading as Marman Trading (Marman), operated a chemical depot adjoining Universal’s plant. Q.C. Human Resources Management Corporation (Resources) supplied Universal with about seventy‑four temporary workers.
On December 13, 2000, Rodolfo Capocyan, claiming to represent the labor organization Obrero Pilipino (Universal Aquarius Chapter), sent a Notice of Strike to Universal. On December 19, 2000, Capocyan and 36 named officers and members picketed and obstructed entry and exit to Universal’s plant and intercepted delivery trucks, disrupting Universal’s and Marman’s operations. Resources notified DOLE that the picketing individuals were its employees.
On December 27, 2000, Universal and Tan filed a complaint in the Regional Trial Court (RTC), Branch 74, Antipolo City, docketed as Civil Case No. 00‑6029, alleging breach of contract and damages resulting from the disruption; Resources was named as a defendant for having supplied the temporary workers. Universal and Obrero Pilipino executed an Agreement “To End Labor Dispute” on January 3, 2001, after which Universal and Tan filed a Notice of Dismissal as to the individual strikers.
Resources moved to dismiss on January 8, 2001, arguing among others that the complaint stated no cause of action against it and that any cause of action was lost when the case against the strikers was dismissed. The RTC denied the motion in an Order dated February 2, 2001, and denied reconsideration on May 11, 2001.
Resources then filed a petition for certiorari and prohibition with the Court of Appeals (CA) on July 11, 2001 (CA‑G.R. SP No. 65570). The CA, in a Decision penned by Associate Justice Sergio L. Pestano dated August 23, 2002, set aside the RTC orders and dismissed the complaint for lack of cause of action, reasoning that Universal’s settlement with the strikers and the dismissal of the case against them erased plaintiffs’ cause of action against Resources. The CA denied reconsideration in a Resolution dated October 22, 2002.
Universal and Tan brought a Pe...(Pro-only)
Issues:
- Did the complaint against Q.C. Human Resources Management Corporation state a cause of action such that the RTC properly denied the motion to dismiss under Rule 16, Sec. 1(g) of the 1997 Rules of Civil Procedure?
- Did the dismissal by the Court of Appeals of the complaint for lack of cause of action constitute a proper exercise of certiorari, and did the RTC commit grave abuse of discretion in denying the motion to dismiss?
- Can Q.C. Human Resources Management Corporation be held liable to Conchita Tan for damages caused by its employees’ strike, i.e., were the employees acting within the scope of their employment so as to impute l...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)