Case Digest (G.R. No. 154060)
Facts:
Yusen Air and Sea Service Philippines, Incorporated hired Isagani A. Villamor in 1993; Villamor resigned on February 1, 2002 and promptly joined Aspac International, a competitor. On February 11, 2002 petitioner filed in the Regional Trial Court, Paranaque (Civil Case No. 02-0063) a complaint for injunction and damages alleging breach of a two-year post-employment non‑competition policy; respondent filed a motion to dismiss and a separate illegal dismissal case before the NLRC.The RTC, Branch 258, dismissed the complaint for lack of jurisdiction on March 20, 2002 and denied reconsideration on June 21, 2002, prompting this Rule 45 petition to the Supreme Court.
Issues:
- Did petitioner’s action for damages arise from employer-employee relations and thus fall within the exclusive jurisdiction of the Labor Arbiter under Article 217?
- Did the lapse of the two-year prohibitory period render petitioner’s prayer for injunctive relief moot?
Ruling:
The Supreme Court set aside the RT Case Digest (G.R. No. 154060)
Facts:
- Parties and corporate background
- Yusen Air and Sea Service Philippines, Incorporated (Petitioner) is a corporation organized under Philippine law engaged in the business of freight forwarding, including pick-up, unpacking, consolidation, delivery, transport and distribution of cargo, and entering into charter parties.
- Isagani A. Villamor (Respondent) was hired by Yusen on August 16, 1993 as branch manager of its Cebu office and was later reclassified as Division Manager.
- Employment, resignation and subsequent employment
- Respondent resigned from petitioner effective February 1, 2002.
- Immediately after his resignation, respondent commenced employment with Aspac International, a corporation engaged in the same line of business as petitioner.
- Contractual restriction alleged and text of undertaking
- Petitioner alleged respondent had signed an undertaking to abide by company policies, including the provision: "No employee may engage in any business or undertaking that is directly or indirectly in competition with that of the company and its affiliates ... The same provision will be implemented for a period of two (2) years from the date of an employee's resignation, termination or separation from the company."
- Petitioner alleged respondent violated the foregoing undertaking by joining Aspac International within two years from his resignation.
- Complaint filed and reliefs sought
- On February 11, 2002 petitioner filed a complaint for injunction and damages with prayer for a temporary restraining order in the Regional Trial Court (RTC), Paranaque City, docketed as Civil Case No. 02-0063, Branch 258.
- Petitioner prayed for an injunction enjoining respondent from "further pursuing his work at Aspac International" and for P2,000,000 as actual damages, P300,000 as exemplary damages, and P300,000 as attorney's fees.
- Concurrent labor action and defensive pleading
- On March 4, 2002 respondent filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC).
- Instead of filing an answer in Civil Case No. 02-0063, respondent filed a Motion to Dismiss asserting the RTC lacked jurisdiction because the case involved an employer-employee relationship.
- Trial court disposition and motion for reconsideration
- By order dated March 20, 2002, the RTC dismisse...(Subscriber-Only)
Issues:
- Jurisdictional issue
- Whether petitioner’s claim for damages arose from employer-employee relations and therefore fell within the exclusive original jurisdiction of the Labor Arbiter under Article 217 of the Labor Code as amended.
- Provisional relief and justiciability issue
- Whether the prayer for injunctive relief...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)