871 Phil. 514; 117 OG No. 43, 10140 (October 25, 2021)
INTING, J.:
WHEREFORE, PREMISES CONSIDERED, judgment is hereby rendered ordering the respondent corporation SAN MIGUEL YAMAMURA PACKAGING CORPORATION to pay complainant the following:Respondent appealed to the NLRC. It posted the full amount of the judgment award but subsequently moved to reduce the required bond on the ground that the amount of P1,400,000.00 had already been consigned before the RTC in connection with the Complaint for Interpleader with Consignation it previously filed.[28]Or in the total aggregate sum of TWO MILLION THREE HUNDRED THIRTY SEVEN THOUSAND SEVEN HUNDRED FIFTY FIVE PESOS AND 2/100 (P2,337,755.02)[.]
Refund of the deductions since March 2007 P 529,464.00Separation Pay Withheld P 1,400.000.00Plus 6% interest P 115,767.84Moral Damages P 50,000.00Exemplary Damages P 30,000.00 P 2,125,231.8410% Attorneys Fees P 212,523.18
Other claims are denied for lack of merit and basis.
SO ORDERED.[27]
WHEREFORE, the Petition is GRANTED. The Decision and Resolution dated March 1, 2016 and May 18, 2016, respectively, as well as all other issuances and proceedings rendered in NLRC Case No. VAC-02-000081-2016, are NULLIFIED and SET ASIDE.The CA found that petitioner was not seeking to enforce his rights under the Labor Code, other labor statutes, or any collective bargaining agreement, and his claims could not be resolved by referring to labor law provisions.[38] On the contrary, the CA held that the money claim presented before the labor tribunal relates, on the one hand, to petitioner's supposed financial obligations to the Cooperative, if there were still any; and on the other hand, to respondent's contractual obligation to the Cooperative pursuant to the MOA provision wherein respondent undertook to deduct any unpaid loan balances from the final pay of the borrower-employee in the event of his/her retirement, resignation, or termination.[39] To the CA, the determination of these matters does not require the expertise in labor management relations, wage structures or other terms and conditions of employment; rather, it entails the application of civil law, particularly on obligations and contracts.[40]
SO ORDERED.[37]
I
AS A MATTER OF LAW, LABOR COURTS HAVE JURISDICTION OVER, AND THE AUTHORITY TO AWARD, EMPLOYMENT BENEFITS SUCH AS SEPARATION PAY. THUS, THE COURT OF APPEALS GRAVELY ERRED WHEN IT HELD THAT THE LABOR COURT HAS NO JURISDICTION OVER THE SUBJECT MATTER.II
THE HONORABLE COURT ERRED WHEN IT HELD THAT THE ISSUES IN THIS CASE DO NOT REQUIRE THE APPLICATION OF ANY LABOR LAWS.[41]
While we have upheld the present trend to refer worker-employer controversies to labor courts in light of the aforequoted provision, we have also recognized that not all claims involving employees can be resolved solely by our labor courts, specifically when the law provides otherwise. For this reason, we have formulated the "reasonable causal connection rule," wherein if there is a reasonable causal connection between the claim asserted and the employer-employee relations, then the case is within the jurisdiction of the labor courts; and in the absence thereof, it is the regular courts that have jurisdiction. Such distinction is apt since it cannot be presumed that money claims of workers which do not arise out of or in connection with their employer-employee relationship. and which would therefore fall within the general jurisdiction of the regular courts of justice, were intended by the legislative authority to be taken away from the jurisdiction of the courts and lodged with Labor Arbiters on an exclusive basis.[49]To the Court, petitioner's claims have no "reasonable causal connection" with his employment relationship with respondent. It bears to point out that the case that petitioner filed was neither a complaint for illegal dismissal nor a claim for reinstatement. His complaint was for alleged non-payment of separation benefits and damages. It is notable, however, that respondent never denied petitioner's entitlement to his separation pay. In fact, on October 13, 2014, respondent paid out petitioner's separation package, except that it withheld the amount of P1,400,000.00, which, purportedly, was his outstanding indebtedness to the Cooperative.[50] Petitioner, in turn, signed a Receipt and Release in favor of respondent but made notation that the amount of P1,400,000.00 was still subject to verification.[51] Thus, by signing the Receipt and Release, petitioner had in fact acknowledged that he had been paid all amounts due him comprising his separation benefits, except that he questioned the withholding of the P1,400,000.00 as he claimed that he no longer had existing loan obligations to the Cooperative. It appears, thus, that the principal relief sought by petitioner in his complaint was not the payment of his separation package but the release to him of the withheld amount of P1,400,000.00, to which both he and the Cooperative claimed entitlement. In addition, he also sought the return of the alleged excess deductions made for his 2007 loan in the amount of P279,464.00.
Not every controversy or money claim by an employee against the employer or vice-versa is within the exclusive jurisdiction of the labor arbiter. 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. Here, the employer-employee relationship between the parties is merely incidental and the cause of action ultimately arose from different sources of obligation, i.e., the Constitution and CEDAW.Here, since both petitioner and the Cooperative claimed entitlement to the withheld amount of P1,400,000.00, respondent appropriately filed a Complaint for Interpleader with Consignation before Branch 55 of the RTC of Mandaue City. Under Section 1, Rule 62 of the Rules of Court, a person may file a special civil action for interpleader if conflicting claims are made against him/her/it over a subject matter in which he/she/it has no interest. The action is brought against the claimants to compel them to litigate their claims among themselves. Section 1, Rule 62 of the Rules of Court provides:
Thus, where the principal relief sought is to be resolved not by reference to the Labor Code or other labor relations statute or a collective bargaining agreement but by the general civil law, the jurisdiction over the dispute belongs to the regular courts of justice and not to the labor arbiter and the NLRC. In such situations, resolution of the dispute requires expertise, not in labor management relations nor in wage structures and other terms and conditions of employment, but rather in the application of the general civil law. Clearly, such claims fall outside the area of competence or expertise ordinarily ascribed to labor arbiters and the NLRC and the rationale for granting jurisdiction over such claims to these agencies disappears.[53]
SECTION 1. When interpleader proper. - Whenever conflicting claims upon the same subject matter are or may be made against a person who claims no interest whatever in the subject matter, or an interest which in whole or in part is not disputed by the claimants, he may bring an action against the conflicting claimants to compel them to interplead and litigate their several claims among themselves.It bears emphasis that the interpleader case before the RTC was filed prior to petitioner's filing of his complaint before the LA. The fact that respondent filed the interpleader case is even an indication of good faith on its part as both petitioner and the Cooperative would be given the right to have their respective claims ventilated before the court. Contrarily, the Cooperative who is not a party to the labor complaint before the LA would not have the opportunity to oppose or refute petitioner's unilateral claims therein. In addition, the fact that respondent had consigned the amount of P1,400,000.00 in the RTC where the interpleader case was pending demonstrates the lack of intention on its part to deprive petitioner of such amount, if he was indeed the one entitled to it.
When the Corporation filed its Position Paper, it wasted no time to inform the labor arbiter that prior to Tumaodos' filing of his money claim complaint, there was already an Interpleader with Consignation case before the RTC, since the amount subject of Tumaodos' money claim was also being claimed by the Cooperative. This fact should have cautioned the [LA], and later the NLRC, that the subject matter of the case is beyond their competence.The Court also finds that the LA and the NLRC erred in ordering the refund to petitioner of the amount of P529,464.00, the total deductions on his salary which started in March 2007. According to petitioner, respondent made total deductions amounting to P529,464.00 and he had made an excess payment of P279,464.00, which respondent must return. Thus, petitioner had in fact admitted that he was indebted to the Cooperative but only for the amount of P250,000.00; yet, the LA and the NLRC both found proper the refund of P529,464.00 based on their conclusion that this whole amount constituted an illegal deduction on his salary. In any case, the Court finds that the refund of either P529,464.00 or P279,464.00 has no sufficient basis. To reiterate, the presentation of all pertinent loan documents is necessary in order to arrive at a complete and just resolution of the case. Apparently, this cannot be possible in this labor complaint filed by petitioner against respondent considering that the Cooperative is not afforded the opportunity to present its own evidence and the determination of the case would be based merely on the unilateral claims of petitioner.
Noteworthy, Tumaodos himself admitted being a member of the Cooperative and having incurred a loan therefrom in 2007. Considering these circumstances, the determination of Tumaodos' entitlement to the amount he was claiming could not, and should not just be made to rest on his bare allegation. Instead, the adjudicating body should entail the presentation of loan documents, payment slips, and other documents to support Tumaodos' and the Cooperative's respective claims. The [LA] and the NLRC's area of competence or expertise simply do not encompass these matters; hence, the said labor tribunals should have prudently dismissed the case and yielded to the jurisdiction of the RTC. x x x[57]