Case Summary (G.R. No. 209011)
Factual Background
Alibudbud was hired by Malayan on July 5, 2004, as Senior Vice President for its Sales Department. As part of her employment agreement, she acquired a 2004 Honda Civic under a financing plan that required her to remain employed for three years. If she resigned or was terminated before this period, she was obliged to pay the full outstanding balance for the vehicle. Her financial obligation was formalized through a Promissory Note and a Deed of Chattel Mortgage, detailing payment schedules, interest rates, and penalties for non-compliance.
Employment Termination and Subsequent Disputes
Alibudbud was dismissed on July 18, 2005, due to redundancy. Malayan demanded the return of the vehicle; however, Alibudbud refused. Consequently, Malayan filed a replevin action in the Regional Trial Court (RTC) of Manila seeking possession of the car or payment for the outstanding balance. In a parallel move, Alibudbud initiated a complaint for illegal dismissal before the Labor Arbiter, asserting her rights and seeking reinstatement.
Legal Actions and Claims
Alibudbud's counterarguments included the assertion of reasonable depreciation on the vehicle's cost and filed claims for damages against Malayan. Multiple motions for the suspension of the replevin proceedings were raised on the grounds that the labor case created a prejudicial question affecting her obligations under the Promissory Note. The RTC consistently denied these motions, citing the separability of the legal issues involved.
Regional Trial Court's Ruling
In a subsequent decision dated November 28, 2008, the RTC ruled in favor of Malayan, emphasizing Alibudbud's obligation to pay for the car and clarifying that the resolution of her labor dispute did not materially affect the replevin action, which was rooted in the contractual obligations outlined in the Promissory Note and Deed of Chattel Mortgage.
Court of Appeals Decision
However, upon appeal, the Court of Appeals ruled on May 15, 2013, that the RTC lacked jurisdiction over the replevin action due to the underlying employer-employee relationship. The CA noted that Alibudbud's benefits from the Car Financing Plan were contingent on her employment status. Thus, it dismissed the replevin action based on the principle that jurisdiction can be raised at any stage of the proceedings.
Supreme Court's Ruling
The Supreme Court found merit in Malayan's petition. It cited established principles of law concerning replevin, indicating the RTC's rightful jurisdiction over th
...continue readingCase Syllabus (G.R. No. 209011)
Overview of the Case
- The case involves a Petition for Review under Rule 45 of the 1997 Rules of Court filed by Malayan Insurance Company, Inc. against Diana P. Alibudbud.
- The petition seeks to reverse the Decision dated May 15, 2013, and Resolution dated September 6, 2013, of the Court of Appeals (CA) in CA-G.R. CV No. 92940, which dismissed Malayan's complaint for replevin against Alibudbud due to lack of jurisdiction.
Factual Background
- Diana P. Alibudbud was employed as Senior Vice President (SVP) in Malayan's Sales Department starting July 5, 2004.
- She was provided a 2004 Honda Civic sedan under a Car Financing Plan, which stipulated:
- Continuous service for three years from the car's availment date.
- Obligation to pay Malayan's 100% share and outstanding balance if she resigned or was terminated before three years.
- Alibudbud executed a Promissory Note and a Deed of Chattel Mortgage, detailing:
- A loan of P360,000.00 payable in 60 monthly installments at P7,299.50.
- Immediate payment of Malayan's 50% equity share or P360,000.00 if she left before three years.
- Authority for Malayan to apply any amounts due to her against her obligations.
- Penalties for late payments and the right of Malayan to foreclose the mortgage if payments were not made.
- Alibudbud was dismissed from Malayan on July 18, 2005, due to redundancy and subsequently refused to surrender the car.
- Malayan filed a Complaint for replevin on September 21, 2005, seeki