Almirante: Jurisdiction not in NLRC but RTC

Labor Case Digest

DUE to its plant reorganization, respondent San Miguel Yamura Packaging Corp. implemented an Involuntary Separation Program. Petitioner Trifon B. Tumaodos was one of its employees who availed himself of the program. His separation package was computed at P3,084,244.66, but respondent withheld the amount of P1,400,000.00 on behalf of the cooperative to which petitioner allegedly had an outstanding indebtedness.

Subsequently, respondent received a letter from petitioner claiming he no longer had an outstanding obligation in the cooperative. Thus, petitioner demanded the release of the withheld amount. Respondent also received a letter from the cooperative disputing petitioner’s assertions and also claiming entitlement to the withheld amount. Due to the conflicting claims respondent filed a complaint for Interpleader with Consignation before Branch 55, Regional Trial Court, Mandaue City.

Meanwhile, petitioner filed a complaint against respondent before the National Labor Relations Commission (NLRC) Regional Arbitration Branch No. VII for non-payment of separation pay and damages. Respondent claimed that the Labor Arbiter (LA) and the NLRC have no jurisdiction over the case.

Does this claim prosper?

Ruling: Yes.

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 Oct. 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. Petitioner, in turn, signed Receipt and Release in favor of respondent but made a notation that the amount of P1,400,000.00 was still subject to verification. 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.

Ergo, given that the disputed amount of P1,400,000.00 and the alleged excess deductions of P279,464.00 both relate to petitioner’s alleged indebtedness to the cooperative and not to respondent, it becomes apparent that the controversy involves debtor-creditor relations between petitioner and the cooperative, rather than employer-employee relations between respondent and petitioner. Evidently, the employer-employee relationship between respondent and petitioner in this case is merely incidental and the principal relief sought by petitioner can 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.

In sum, the determination of petitioner’s case is beyond the competence of the labor tribunals for the following reasons: 1) petitioner’s claims have no reasonable causal connection with his employment relationship with respondent; 2) the cooperative is not a party to the labor complaint and would therefore be deprived of the opportunity to plead its claims; and 3) the Interpleader with Consignation case before the Regional Trial Court, which was filed by respondent prior to petitioner’s labor complaint, was the proper forum to ventilate the claimants’ respective claims over the disputed amount of P1,400,000.00. (Trifon B. Tumaodos vs. San Miguel Yamamura Packaging Corp., G.R. 241865, Feb. 19, 2020).


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