GROTJAHN GMBH vs. ISNANI

 

August 10, 1994; G.R. No. 109272

Topic:  Effect when no employer-employee relationship exists/issue does not involve employer-employee relationship

FACTS:

Petitioner is a multinational corporation (employer).  Private respondent Lanchinebre (employee) worked as its sales representative from 1983 to mid-1992.  Employee obtained loans and cash advances, a total of P12,170.37 remained unpaid. 

In July 1992, Employee filed an illegal suspension case with the NLRC (NLRC Case).  Employer, on the other hand, filed a case for collection of Sum of Money at the RTC (Collection Case).  Employee moved to dismiss the collection case on the ground that the case was in the nature of a claim for employee compensation (Art 217 No.4 & 6) and was under the exclusive jurisdiction of the NLRC.  The RTC under respondent judge dismissed the case.

Hence this petition for review.

ISSUE:

Whether or not the RTC has jurisdiction over the Collection Case.

HELD:

YES.  While the loans and cash advances were contracted between employee and employer during the subsistence of their relationship, it does not follow that Article 217 of the Labor Code covers their relationship.

The SC writes:

Not every dispute between an employer and employee involves matters that only labor arbiters and the NLRC can resolve in the exercise of their adjudicatory or quasi-judicial powers. The jurisdiction of labor arbiters and the NLRC under Article 217 of the Labor Code is limited to disputes arising from an employer-employee relationship which can only be resolved by reference to the Labor Code, other labor statutes, or their collective bargaining agreement. …

xxx

Civil Case No. 92-2486 is a simple collection of a sum of money brought by petitioner, as creditor, against private respondent Romana Lanchinebre, as debtor. The fact that they were employer and employee at the time of the transaction does not negate the civil jurisdiction of the trial court. The case does not involve adjudication of a labor dispute but recovery of a sum of money based on our civil laws on obligation and contract.

xxx

Whether or not the subject loan was incurred by private respondent as an incident to her profession, occupation or business is a question of fact. In the absence of relevant evidence, the issue cannot be resolved in a motion to dismiss.

Thus the relevant test in this instance is the test of relevance.  Specifically, whether or not the Labor Code has any relevance to the reliefs being sought by the parties.  If none, the case may be considered as intrinsically a civil dispute.

The order of the RTC was reversed and the collection case was reinstated.