Mindanao State University

MSU College of Law

Iligan Extension

CASE DIGESTS
and
CASE DOCTRINES

In Compliance for the Course Subject on Labor Law Review

Submitted by:
GROUP 1

Dennis F. Obial
Cris Albert Oliva
Nathan Ray Rudinas
LyraMizarO. Mijares
Roa Day H. Yuson

Fifth Year
Submitted to:
Labor Arbiter Abdul Azis U. Metmug
September 14, 2019

1. ​G.R. No. 152121. July 29, 2003

EDUARDO G. EVIOTA, petitioner, vs. THE HON. COURT OF APPEALS, THE HON. JOSE
BAUTISTA, Presiding Judge of Branch 136, Regional Trial Court of Makati, and STANDARD
CHARTERED BANK, respondents.

FACTS:

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 Sometime on January 26, 1998, the respondent Standard Chartered Bank and petitioner Eduardo G.
Eviota executed a contract of employment under which the petitioner was employed by the respondent
bank as Compensation and Benefits Manager, VP (M21). Petitioner came up with many proposals which
the bank approved and made preparations of. He was also given privileges like car, renovation of the
office, and even a trip to Singapore at the company’s expense. However, the petitioner abruptly resigned
from the respondent bank barely a month after his employment and rejoined his former employer. On
June 19, 1998, the respondent bank filed a complaint against the petitioner with the RTC of Makati City
for damages brought about his abrupt resignation.

Though petitioner reimbursed part of the amount demanded by Standard, he was not able to pay it full.

Standard alleged that assuming arguendo that Eviota had the right to terminate his employment with the
Bank for no reason, the manner in and circumstances under which he exercised the same are clearly
abusive and contrary to the rules governing human relations, governed by the Civil Code.

Further, Standard alleged that petitioner also violated the Labor Code when he terminated his employment
without one (1) notice in advance. This stipulation was also provided in the employment contract of
Eviota with Standard, which would also constitute breach of contract.

The petitioner filed a motion to dismiss the complaint on the ground that the action for damages of the
respondent bank was within the exclusive jurisdiction of the Labor Arbiter under paragraph 4, Article 217
of the Labor Code of the Philippines, as amended. The petitioner averred that the respondent bank’s
claim for damages arose out of or were in connection with his employer-employee relationship with the
respondent bank or some aspect or incident of such relationship. The respondent bank opposed the
motion, claiming that its action for damages was within the exclusive jurisdiction of the trial court.
Although its claims for damages incidentally involved an employer-employee relationship, the said
claims are actually predicated on the petitioner’s acts and omissions which are separately, specifically and
distinctly governed by the New Civil Code.

ISSUE: Whether or not the RTC had jurisdiction over the case.

HELD:

The SC held that the RTC has jurisdiction. Case law has it that the nature of an action and the subject
matter thereof, as well as which court has jurisdiction over the same, are determined by the material
allegations of the complaint and the reliefs prayed for in relation to the law involved. Not every
controversy or money claim by an employee against the employer or vice-versa is within the exclusive
jurisdiction of the labor arbiter. A money claim by a worker against the employer or vice-versa is within
the exclusive jurisdiction of the labor arbiter only if there is a “reasonable causal connection” between the
claim asserted and employee-employer relation. Absent such a link, the complaint will be cognizable by
the regular courts of justice.

Actions between employees and employer where the employer-employee relationship is merely incidental
and the cause of action precedes from a different source of obligation is within the exclusive jurisdiction
of the regular court. The jurisdiction of the Labor Arbiter under Article 217 of the Labor Code, as
amended, is limited to disputes arising from an employer-employee relationship which can only be
resolved by reference to the Labor Code of the Philippines, other labor laws or their collective bargaining
agreements.

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 Jurisprudence has evolved the rule that claims for damages under paragraph 4 of Article 217, to be
cognizable by the Labor Arbiter, must have a reasonable causal connection with any of the claims
provided for in that article. Only if there is such a connection with the other claims can the claim for
damages be considered as arising from employer-employee relations.

In this case, the private respondent’s first cause of action for damages is anchored on the petitioner’s
employment of deceit and of making the private respondent believe that he would fulfill his obligation
under the employment contract with assiduousness and earnestness. The petitioner volte face when,
without the requisite thirty-day notice under the contract and the Labor Code of the Philippines, as
amended, he abandoned his office and rejoined his former employer; thus, forcing the private respondent
to hire a replacement. The private respondent was left in a lurch, and its corporate plans and program in
jeopardy and disarray. Moreover, the petitioner took off with the private respondent’s computer diskette,
papers and documents containing confidential information on employee compensation and other bank
matters. On its second cause of action, the petitioner simply walked away from his employment with the
private respondent sans any written notice, to the prejudice of the private respondent, its banking
operations and the conduct of its business. Anent its third cause of action, the petitioner made false and
derogatory statements that the private respondent reneged on its obligations under their contract of
employment; thus, depicting the private respondent as unworthy of trust.

The primary relief sought is for liquidated damages for breach of a contractual obligation. The other
items demanded are not labor benefits demanded by workers generally taken cognizance of in labor
disputes, such as payment of wages, overtime compensation or separation pay. The items claimed are the
natural consequences flowing from breach of an obligation, intrinsically a civil dispute.

It is evident that the causes of action of the private respondent against the petitioner do not involve the
provisions of the Labor Code of the Philippines and other labor laws but the New Civil Code. Thus, the
said causes of action are intrinsically civil. There is no causal relationship between the causes of action of
the private respondent’s causes of action against the petitioner and their employer-employee relationship.
The fact that the private respondent was the erstwhile employer of the petitioner under an existing
employment contract before the latter abandoned his employment is merely incidental.

Petition is denied.

2. G.R. No. 198587, January 14, 2015

SAUDI ARABIAN AIRLINES (SAUDIA) AND BRENDA J. BETIA,Petitioners, v.MA.JOPETTE M.
REBESENCIO, MONTASSAH B. SACAR-ADIONG, ROUEN RUTH A. CRISTOBAL AND LORAINE S.
SCHNEIDER-CRUZ, Respondents.

DOCTRINE: Employer-employee relationship is much affected with public interest and that the otherwise
applicable Philippine laws and regulations cannot be rendered illusory by the parties agreeing upon some
other law to govern their relationship.

Contracts relating to labor and employment are impressed with public interest. Article 1700 of the Civil
Code provides that "[t]he relation between capital and labor are not merely contractual. They are so
impressed with public interest that labor contracts must yield to the common good."

Philippine tribunals may properly assume jurisdiction over the present controversy. The immense public
policy considerations attendant to this case behoove Philippine tribunals to not shy away from their duty
to rule on the case.

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 FACTS:

Saud Arabian Airlines (Saudia) is the employer of flight attendants Rebesencio, Sacar-Adiong, Cristobal,
and Schnieder-Cruz. Respondents continued their employment with Saudia until they were separated
from service on various dates in 2006. Respondents contended that the termination of their employment
was illegal. They alleged that the termination was made solely because they were pregnant.

As respondents alleged, they had informed Saudia of their respective pregnancies and had gone through
the necessary procedures to process their maternity leaves. Saudia had disapproved their maternity
leaves and respondents to file their resignation letters.

Saudia anchored its disapproval of respondents' maternity leaves and demand for their resignation.
Saudia anchored its disapproval of respondents' maternity leaves and demand for their resignation on its
on its Unified Employment Contract. Under the Unified Contract, the employment of a Flight Attendant
who becomes pregnant is rendered void.

Rather than comply and tender resignation letters, respondents filed separate appeal letters that were all
rejected. Faced with the dilemma of resigning or totally losing their benefits, respondents executed
handwritten resignation letters.

On November 8, 2007, respondents filed a Complaint against Saudia and its officers for illegal dismissal
and for underpayment before the Labor Arbiter. Saudia assailed the jurisdiction of the Labor Arbiter. It
claimed that all the determining points of contact referred to foreign law and insisted that the Complaint
ought to be dismissed on the ground of forum non conveniens. It added that respondents had no cause of
action as they resigned voluntarily.

The Executive Labor Arbiter dismissed the complaint. However, the NLRC reversed the dismissal on
appeal and ordered Saudia to pay the respondents’ claims. The CA upheld the NLRC decision with
modification with respect to the award.

Before the SC, Saudia asserts that Philippine courts and/or tribunals are not in a position to make an
intelligent decision as to the law and the facts. This is because respondents' Cabin Attendant contracts
require the application of the laws of Saudi Arabia, rather than those of the Philippines. It claims that the
difficulty of ascertaining foreign law calls into operation the principle of forum non conveniens, thereby
rendering improper the exercise of jurisdiction by Philippine tribunals.

ISSUE:

Whether the Labor Arbiter and the National Labor Relations Commission may exercise jurisdiction over
Saudi Arabian Airlines and apply Philippine law in adjudicating the present dispute.

RULING:

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 YES. Forum non conveniens finds no application and does not operate to divest Philippine tribunals of
jurisdiction and to require the application of foreign law. In this strict sense, forum non conveniens is not
applicable. It is not the primarily pivotal consideration in this case.

While a Philippine tribunal (acting as the forum court) is called upon to respect the parties' choice of
governing law, such respect must not be so permissive as to lose sight of considerations of law, morals,
good customs, public order, or public policy that underlie the contract central to the controversy.

Counter-balancing the principle of autonomy of contracting parties is the equally general rule that
provisions of applicable law, especially provisions relating to matters affected with public policy, are
deemed written into the contract. Put a little differently, the governing principle is that parties may not
contract away applicable provisions of law especially peremptory provisions dealing with matters heavily
impressed with public interest.

It is settled that contracts relating to labor and employment are impressed with public interest. Article
1700 of the Civil Code provides that "[t]he relation between capital and labor are not merely contractual.
They are so impressed with public interest that labor contracts must yield to the common good.

As the present dispute relates to the illegal termination of respondents' employment, this case is
immutably a matter of public interest and public policy. Consistent with clear pronouncements in law and
jurisprudence, Philippine laws properly find application in and govern this case. 'Moreover, as this premise
for Saudia's insistence on the application forum non conveniens has been shattered, it follows that
Philippine tribunals may properly assume jurisdiction over the present controversy.

All told, the considerations for assumption of jurisdiction by Philippine tribunals as outlined in Bank of
America, NT&SA have been satisfied. First, all the parties are based in the Philippines and all the material
incidents transpired in this jurisdiction. Thus, the parties may conveniently seek relief from Philippine
tribunals. Second, Philippine tribunals are in a position to make an intelligent decision as to the law and
the facts. Third, Philippine tribunals are in a position to enforce their decisions. There is no compelling
basis for ceding jurisdiction to a foreign tribunal. Quite the contrary, the immense public policy
considerations attendant to this case behoove Philippine tribunals to not shy away from their duty to rule
on the case.

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