G.R. No. 89621 Case Digest

G.R. No. 89621 September 24, 1991

Pepsi Cola

vs Hon. Lolita Gal-ang

Ponente: Cruz

Facts:

Some employees of Pepsi were suspected of irregular disposition of empty pepsi bottles. On July 1987, pepsi filed a criminal complaint for theft against the employees but later withdrawn it for falsification of private documents. The MTC Leyte, after conducting a preliminary investigation dismissed the complaint, with a separate civil complaint against Pepsi for damages due to their malicious prosecution.

Pepsi moved to dismiss the civil complaint on the ground of no jurisdiction because it involved an employee-employer relationship which exclusive under the labor arbiter's jurisdiction. The motion was granted. However, Hon. Gal-ang , acting on a motion for reconsideration, reinstated the case saying that it was distinct from labor case for damages. The petitioners then came to SC for relief.

Pepsi cited Getz Corp vs CA when the court said that "for unpaid salary and other employment benefits, termination pay and moral and exemplary damages" the labor arbiter shall have the jurisdiction over the case.

Issue: Whether there the labor arbiter has the jurisdiction over the case for malicious prosecution?

Ruling:

SC: Not every controversy involving workers and their employers can be resolved only by the labor arbiters. This will be so if there is a "reasonable causal connection" between the claims asserted. Absence the link, it will be under the civil or criminal jurisdiction of the regular courts.

At the case at bar, it involves a complaint for damages for malicious prosecution which does not appear that there is a "reasonable causal connection" between the complaint and the relations of the parties. The complaint did not arise from such relations and in fact could have arisen independently of an employment relationship between the parties.