16 TUCP vs Coscolluela 17 Primero vs IAC 18PEPSI COLA DISTRIBUTOR PHILSvs

16 tucp vs coscolluela 17 primero vs iac 18pepsi cola

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with the petition for custody of minors under Rule 99 of the Rules of Court. 16. TUCP vs. Coscolluela 17. Primero vs. IAC 18.PEPSI COLA DISTRIBUTOR PHILS.vs. GALANG, September 24,1991 Facts: The private respondents were employees of the petitioner who were suspected of complicity in the irregular disposition of empty Pepsi Cola bottles. On July 16, 1987, the petitioners filed a criminal complaint for theft against them but this was later withdrawn and substituted with a criminal complaint for falsification of private documents. After a preliminary investigation conducted by the Municipal Trial Court of Tanauan, Leyte, the complaint was dismissed. Allegedly after an administrative investigation, the private respondents were dismissed by the petitioner company on November 23, 1987. As a result, they lodged a complaint for illegal dismissal with the Regional Arbitration Branch of the NLRC in Tacloban City and decisions mandateed reinstatement with damages. In addition, they instituted in the Regional Trial Court of Leyte, a separate civil complaint against the petitioners for damages arising from what they claimed to be their malicious prosecution. The petitioners moved to dismiss the civil complaint on the ground that the trial court had no jurisdiction over the case because it involved employee- employer relations that were exclusively cognizable by the labor arbiter. The motion was granted .On July 6, 1989, however, the respondent judge, acting on the motion for reconsideration, reinstated the complaint, saying it was “distinct from the labor case for damages now pending before the labor courts.” The petitioners then came to this Court for relief. Issue: Whether or not RTC has jurisdiction over the claim for damages arising from the malicious prosecution of the petitioner company. Held: It must be stressed that not every controversy involving workers and their employers can be resolved only by the labor arbiters. This will be so only if there is a “reasonable causal connection” between the claim asserted and employee-employer relations to put the case under the provisions of Article 217. Absent such a link, the complaint will be cognizable by the regular courts of justice in the exercise of their civil and criminal jurisdiction. In Medina v. Castro-Bartolome, 3 two employees filed in the Court of First Instance of Rizal a civil complaint for damages against their employer for slanderous remarks made against them by the company president. On the order dismissing the case because it came under the jurisdiction of the labor arbiters, Justice Vicente Abad Santos said for the Court: It is obvious from the complaint that the plaintiffs have not alleged any unfair labor practice. Theirs is a simple action for damages for tortious acts allegedly committed by the defendants. Such being the case, the governing statute is the Civil Code and not the Labor Code. It results that the orders under review are based on a wrong premise.
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