G.R. No. 196962 - People vs. Sonjaco y Sta. Ana

Universal Aquarius, Inc. is engaged in the manufacture and distribution of chemical products in Metro Manila and operates a chemical plant in Antipolo City.
Conchita Tan, doing business as Marman Trading, engages in the trading, delivery, and distribution of chemical products in Metro Manila with a depot adjacent to Universal’s plant.
Q.C. Human Resources Management Corporation (Resources) is a manpower firm that supplies temporary workers to various establishments, including Universal Aquarius, Inc.

On December 13, 2000, Rodolfo Capocyan—alleging to be the general counsel/national president of Obrero Pilipino (the labor organization under the Universal Aquarius Chapter)—sent a Notice of Strike to Universal.
On the same day, Resources informed the Department of Labor and Employment that the striking workers were its employees, not those of Universal.
On December 19, 2000, Capocyan and 36 other union officers and members picketed, barricaded, and obstructed the entry and exit of Universal’s chemical plant.
A similar blockade ensued at Marman Trading’s depot, adjacent to Universal’s facility, thereby disrupting business operations at both locations.

On December 27, 2000, Universal Aquarius, Inc. and Conchita Tan filed a Complaint before the Regional Trial Court (RTC), Branch 74, Antipolo City, alleging breach of contract and damages due to disruption of business operations caused by the strike.
The Complaint charged that:

Defendants, led by Capocyan, willfully and unlawfully obstructed Universal’s and Marman’s premises through picketing and barricading.
The resultant disruption led to a standstill in business operations, causing damages including loss of sales.
Resources, by supplying temporary workers who proved inadequate and allegedly inclined to participate in the strike, was indirectly responsible for the damages suffered.

Subsequently, on January 3, 2001, Universal Aquarius entered into an Agreement (To End Labor Dispute) with Obrero Pilipino, effectively ending the strike. Universal and Tan then filed a Notice of Dismissal against the strikers.

On January 8, 2001, Resources filed a Motion to Dismiss the complaint on several grounds:

The complaint stated no cause of action against Resources.
The dismissal of the claims against individual strikers should render the claim against Resources moot.
Lack of jurisdiction over the party.

The RTC denied the Motion to Dismiss on February 2, 2001, and later denied Resources’ Motion for Reconsideration on May 11, 2001.
Resources then filed a petition for certiorari and prohibition with the Court of Appeals (CA) on July 11, 2001.
On August 23, 2002, the CA reversed the RTC’s orders by dismissing the complaint for lack of a cause of action, reasoning that:

The strike—being the source of the disruption—eliminated the cause of action once the dispute was settled.
Resources was implicated solely by its role as the employer of the strikers, not by any direct wrongful act.

Universal and Tan subsequently filed a Motion for Reconsideration before the CA, which was denied in the CA Resolution dated October 22, 2002.

Universal Aquarius, Inc. and Conchita Tan petitioned for review under Rule 45 of the Rules of Court.
They contended that:

The CA erred in dismissing their complaint against Resources by arguing lack of cause of action.
The allegations in their Complaint, particularly relating to the breach of contract involving Resources’ failure to supply fit temporary workers, were sufficient to confer jurisdiction on the RTC.
The claim for damages tied to the strike should be distinguished between the parties, being valid for Universal but not for Tan, given the differing bases of their allegations.

Whether the Complaint sufficiently stated a cause of action against Q.C. Human Resources Management Corporation, given that Resources was implicated only through its role as the supplier of temporary workers, and whether this allegation, if true, would justify the relief demanded by Universal Aquarius, Inc.
Whether the dismissal of the complaint for lack of cause of action was proper considering that the disruption to Universal’s business arose from the strike and the alleged contractual breach by Resources in supplying unsuitable manpower.
Whether the claim for damages by Conchita Tan, which arose solely from the strike, falls within the ambit of employer liability for the acts of employees, particularly when such conduct was outside the scope of their employment.