Tanjay Water District vs.

Gabaton
GR No. 63742, April 17,1989
FACTS:
On March 3, 1983, petitioner Tanjay Water District, fled in the Regional Trial Court Civil
Case No. 8144 an action for injunction with preliminary mandatory injunction and
damages, against respondent Municipality of Pamplona and its ofcials to prevent them
from interfering in the management of the Tanjay Waterworks System.
On March 25, 1983, respondent Judge issued an order dismissing the complaint for lack of
jurisdiction over the subject matter (water) and over the parties (both being government
instrumentalities) by virtue of Art. 88 of PD No. 1067 and PD No. 242. He declared that the
petitioner's recourse to the court was premature because the controversy should have
been ventilated frst before the National Water Resources Council pursuant to Arts. 88 and
89 of PD No. 1067. He further ruled that as the parties are government instrumentalities,
the dispute should be administratively settled in accordance with PD No. 242.
Petitioner fled a petition for certiorari in this Court alleging that respondent Judge acted
without or in excess of jurisdiction or with grave abuse of discretion in dismissing the case.
ISSUE:
Whether or not the RTC has jurisdiction to hear and decide the dispute in the frst instance.
RULING:
The petition is dismissed. Inasmuch as Civil Case No. 8144 involves the appropriation,
utilization and control of water, We hold that the jurisdiction to hear and decide the dispute
in the frst instance, pertains to the Water Resources Council as provided in PD No. 1067
which is the special law on the subject. The Court of First Instance (now Regional Trial
Court) has only appellate jurisdiction over the case.
P.D. No. 242 is inapplicable to this case because the controversy herein did not arise from
the "interpretation and application of statutes, contracts, or agreements" of the parties
herein. As previously stated, it involves the appropriation, utilization, and control of water.
Wherefore, Petitioners are hereby directed to fle their complaint in the National Water
Resources Council.
SAN MIGUEL CORPORATION vs. NLRC
G.R. No. 80774,May 31, 1988
FACTS:
San Miguel Corporation sponsored an innovation program granting cash awards to
employers who would submit
ISSUE: Whether or not the Labor Arbiter has jurisdiction over money claims which arose
out of or in connection with the private respondent's employment.
RULING:
Money claims of workers which now fall within the original and exclusive jurisdiction of
Labor Arbiters are those money claims which have some reasonable causal connection
with the employer-employee relationship.
The petitioner's Innovation Program is an employee incentive scheme ofered and open
only to employees of petitioner Corporation, more specifcally to employees below the rank
of manager. Without the existing employer-employee relationship between the parties here,
there would have been no occasion to consider the petitioner's Innovation Program or the
submission by Mr. Vega of his proposal concerning beer grande; without that relationship,
private respondent Vega's suit against petitioner Corporation would never have arisen. The
money claim of private respondent Vega in this case, therefore, arose out of or in
connection with his employment relationship with petitioner.
However, the fact that the money claim of private respondent Vega arose out of or in
connection with his employment relation with petitioner Corporation, is not enough to bring
such money claim within the original and exclusive jurisdiction of Labor Arbiters.
Thus, whether or not an enforceable contract, albeit implied and innominate, had arisen
between petitioner Corporation and private respondent Vega in the circumstances of this
case, and if so, whether or not it had been breached, are preeminently legal questions,
questions not to be resolved by referring to labor legislation and having nothing to do with
wages or other terms and conditions of employment, but rather having recourse to our law
on contracts.
BEBIANO M. BAEZ vs. HON. DOWNEY C. VALDEVILLA and ORO MARKETING, INC.,
G.R. No. 128024 May 9, 2000
FACTS:
Petitioner was the sales operations manager of private respondent in its branch in Iligan
City. In 1993, private respondent "indefnitely suspended" petitioner and the latter fled a
complaint for illegal dismissal with the National Labor Relations Commission ("NLRC") in
Iligan City. The Labor Arbiter ruled in favor of the petitioner. Such ruling was appealed by
private respondent to the NLRC, which dismissed the same for having been fled out of
time.
On November 13, 1995, private respondent fled a complaint for damages before the
Regional Trial Court ("RTC") of Misamis Oriental, docketed as Civil Case No. 95-554.
On January 30, 1996, petitioner fled a motion to dismiss the above complaint. He
interposed that the action for damages, having arisen from an employer-employee
relationship, was squarely under the exclusive original jurisdiction of the NLRC under
Article 217(a), paragraph 4 of the Labor Code and is barred by reason of the fnal
judgment in the labor case.
ISSUE: Whether or not regular courts have jurisdiction over claims of damages as between
employees and employers.
RULING:
No. There is no mistaking the fact that in the case before us, private respondent's claim
against petitioner for actual damages arose from a prior employer-employee relationship.
Clearly, respondent court's taking jurisdiction over the instant case would bring about
precisely the harm that the lawmakers sought to avoid in amending the Labor Code to
restore jurisdiction over claims for damages of this nature to the NLRC.
The Supreme Court can not uphold the reasoning of respondent court that because the
resolution of the issues presented by the complaint does not entail application of the Labor
Code or other labor laws, the dispute is intrinsically civil. Article 217(a) of the Labor Code,
as amended, clearly bestows upon the Labor Arbiter original and exclusive jurisdiction over
claims for damages arising from employer-employee relations in other words, the Labor
Arbiter has jurisdiction to award not only the reliefs provided by labor laws, but also
damages governed by the Civil Code.