4 Pepsi Cola V Martinez
4 Pepsi Cola V Martinez
4 Pepsi Cola V Martinez
FACTS
On September 19, 1980, respondent Abraham Tumala, Jr. filed a complaint against
petitioners Pepsi-Cola Bottling Co., Inc., its president Cosme de Aboitiz and other
company officers.
o First cause of action: Tumala was a salesman of the company in Davao City from
1977 up to August 21, 1980; that in the annual "Sumakwel" contest conducted by
the company in 1979, Tumala was declared winner of the "Lapu-Lapu Award" for
his performance as top salesman of the year, earning him a prize of a house and
lot
o Second cause of action: alleged that on August 21, 1980, petitioners ", "arbitrarily
and ilegally" terminated his employment
Petitioners moved to dismiss the complaint
o grounds of lack of jurisdiction and cause of action
o alleged that Tumala was not entitled to the "Sumakwel" prize for having misled
the company into declaring him top salesman for 1979 through various deceitful
and fraudulent manipulations and machinations
ISSUE:
Which tribunal has exclusive jurisdiction over an action filed by an employee against his
employer for recovery of unpaid salaries, separation benefits and damages — the court
of general jurisdiction or the Labor Arbiter of the National Labor Relations Commission
[NLRC]?
RULING:
We rule that the Labor Arbiter has exclusive jurisdiction over the case.
Since the jurisdiction of courts and judicial tribunals is derived exclusively from the
statutes of the forum, the issue efore Us should be resolved on the basis of the law or
statute now in force. We find that law in Presidential Decree 1691 which took effect on
May 1, 1980.
o Under paragraphs 3 and 5 of the above Presidential Decree, the case is
exclusively cognizable by the Labor Arbiters of the National Labor Relations
Commission
It is to be noted that P.D. 1691 is an exact reproduction of Article 217 of the Labor Code
(P.D. 442), which took effect on May 1, 1974
In Garcia vs. Martinez, We held that under Article 217 of the Labor Code, the law then in
force, the case was within the exclusive jurisdiction of the Labor Arbiters and the
National Labor Relations Commission [NLRC].
Art. 217 of the Labor Code was amended by PD 1367, which was promulgated on May,
1, 1978.
However, on May 1, 1980, Article 217, as amended by P.D. 1367, was amended anew
by P.D. 1691. This last decree, which is a verbatim reproduction of the original test of
Article 217 of the Labor Code, restored to the Labor Arbiters of the NLRC exclusive
jurisdiction over claims, money or otherwise, arising from employer-employee relations,
except those expressly excluded therefrom.
The claim for said prize unquestionably arose from an employer-employee relation and,
therefore, falls within the coverage of par. 5 of P.D. 1691, which speaks of "all claims
arising from employer-employee relations, unless expressly excluded by this Code."
Indeed, Tumala would not have qualitfied for the content, much less won the prize, if he
was not an employee of the company at the time of the holding of the contest.
o the cause advanced by petitioners to justify their refusal to deliver the prize—the
alleged fraudulent manipulations committed by Tumala in connection with his
duties as salesman of the company—involves an inquiry into his actuations as an
employee
Besides, to hold that Tumala's claim for the prize should be passed upon by the regular
court of justice, independently and separately from his claim for back salaries, retirement
benefits and damages, would be to sanction split juridiction and multiplicity of suits which
are prejudicial to the orderly administration of justice.