The document summarizes a Supreme Court case between Citibank and Citibank Integrated Guards Labor Alliance (CIGLA). The case determined that there was no labor dispute between Citibank and security guards that were members of CIGLA. This is because Citibank contracted with a security agency, El Toro, and had no direct employer-employee relationship with the guards. When Citibank did not renew its contract with El Toro, it did not constitute a lockout or mass dismissal. Therefore, the security guards had no right to strike against Citibank. The Court also found that the regional trial court properly had jurisdiction over Citibank's complaint against CIGLA, as the dispute was
The document summarizes a Supreme Court case between Citibank and Citibank Integrated Guards Labor Alliance (CIGLA). The case determined that there was no labor dispute between Citibank and security guards that were members of CIGLA. This is because Citibank contracted with a security agency, El Toro, and had no direct employer-employee relationship with the guards. When Citibank did not renew its contract with El Toro, it did not constitute a lockout or mass dismissal. Therefore, the security guards had no right to strike against Citibank. The Court also found that the regional trial court properly had jurisdiction over Citibank's complaint against CIGLA, as the dispute was
The document summarizes a Supreme Court case between Citibank and Citibank Integrated Guards Labor Alliance (CIGLA). The case determined that there was no labor dispute between Citibank and security guards that were members of CIGLA. This is because Citibank contracted with a security agency, El Toro, and had no direct employer-employee relationship with the guards. When Citibank did not renew its contract with El Toro, it did not constitute a lockout or mass dismissal. Therefore, the security guards had no right to strike against Citibank. The Court also found that the regional trial court properly had jurisdiction over Citibank's complaint against CIGLA, as the dispute was
The document summarizes a Supreme Court case between Citibank and Citibank Integrated Guards Labor Alliance (CIGLA). The case determined that there was no labor dispute between Citibank and security guards that were members of CIGLA. This is because Citibank contracted with a security agency, El Toro, and had no direct employer-employee relationship with the guards. When Citibank did not renew its contract with El Toro, it did not constitute a lockout or mass dismissal. Therefore, the security guards had no right to strike against Citibank. The Court also found that the regional trial court properly had jurisdiction over Citibank's complaint against CIGLA, as the dispute was
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Citibank v. Court of Appeals
G.R. No. 108961, 27 November 1998
DOCTRINE/S: Article 212, paragraph 1 of the Labor Code provides the definition of a "labor dispute". It "includes any controversy or matter concerning terms or conditions of employment or the association or representation of persons in negotiating, fixing, maintaining, changing or arranging the terms and conditions of employment, regardless of whether the disputants stand in the proximate relation of employer and employee."
PETITIONER/S: CITIBANK, N.A.,
RESPONDENT/S: COURT OF APPEALS (Third Division), and CITI-BANK INTEGRATED GUARDS LABOR ALLIANCE (CIGLA) SEGA-TUPAS/FSM LOCAL CHAPTER No. 1394, NATURE: petition for review on certiorari
FACT/S: Citibank entered into a contract with El Toro Security Agency El Toro which obligated itself to provide the services of security guards to safeguard and protect the premises of Citibank against theft, robbery, or any other unlawful acts committed by any person or persons, and assumed responsibility for losses and/or damages that may be incurred by Citibank due to or as a result of the negligence of El Toro or any of its assigned personnel. In 1990, the contract between Citibank and El Toro expired. In 1990, respondent Citibank Integrated Guards Labor Alliance-SEGA-TUPAS/FSM (hereafter CIGLA) filed with the National Conciliation and Mediation Board (NCMB) a request for preventive mediation citing Citibank as respondent therein giving as issues for preventive mediation the following: a) Unfair labor practice; b) Dismissal of union officers/members; and c) Union bust. El Toro was served a notice that the bank would not renew anymore the service agreement with the latter. Citibank also hired another security agency. On the same date, June 10, 1990, respondent CIGLA filed a manifestation with the NCMB that it was converting its request for preventive mediation into a notice of strike for failure of the parties to reach a mutually acceptable settlement of the issues. A day after, security guards of El Toro who were replaced by guards of the Golden Pyramid Security Agency considered the non-renewal of El Toro's service agreement with Citibank as constituting a lockout and/or a mass dismissal. They threatened to go on strike against Citibank and picket its premises. In fact, security guards formerly assigned to Citibank under the expired agreement loitered around and near the Citibank premises in large groups of from twenty (20) and at times fifty (50) persons. This prompted respondent CIGLA to file a notice of strike directed at the premises of the Citibank main office.
Citibank filed with the RTC Makati a complaint for injunction and damages seeking to enjoin CIGLA and any person claiming membership therein from striking or otherwise disrupting the operations of the bank. CIGLA, on the other hand, filed a motion to dismiss the complaint alleging, among other, that the Court had no jurisdiction, it being a labor dispute. This was denied by the trial court. CIGLA filed an MoR and averred as special and affirmative defense lack of jurisdiction of the court over the subject matter of the case which was also denied by the RTC. CIGLA filed with the CA a petition for certiorari with preliminary injunction. CA ruled in CIGLA's favor. Citibank's MoR was denied. Hence, the present petition wherein Citibank contends that there is no employer-employee relationship between Citibank and the security guards represented by respondent CIGLA and that there is no "labor dispute" in the subject controversy. The security guards were employees of El Toro security agency, not of Citibank. Its service contract with Citibank had expired and not renewed.
ISSUE/S: Whether or not there was a labor dispute between Citibank and the security guards who are members of respondent CIGLA. HELD: NO. Article 212, paragraph 1 of the Labor Code provides the definition of a "labor dispute". It "includes any controversy or matter concerning terms or conditions of employment or the association or representation of persons in negotiating, fixing, maintaining, changing or arranging the terms and conditions of employment, regardless of whether the disputants stand in the proximate relation of employer and employee."
As held by the Court, the dispute between Citibank and El Toro security agency is one regarding the termination or non-renewal of the contract of services. This is a civil dispute. El Toro was an independent contractor. Thus, no employer-employee relationship existed between Citibank and the security guard members of the union in the security agency who were assigned to secure the bank's premises and property. Hence, there was no labor dispute and no right to strike against the bank.
As to question on whether regional trial court has jurisdiction, it is a basic rule of procedure that "jurisdiction of the court over the subject matter of the action is determined by the allegations of the complaint, irrespective of whether or not the plaintiff is entitled to recover upon all or some of the claims asserted therein. The jurisdiction of the court cannot be made to depend upon the defenses set up in the answer or upon the motion to dismiss, for otherwise, the question of jurisdiction would almost entirely depend upon the defendant." In this case, petitioner alleged in the complaint filed with the trial court that in 1983, it entered into a contract with El Toro, a security agency, for security and protection service. The parties renewed the contract yearly until April 22, 1990. Petitioner further alleged that from June 11, 1990, until the filing of the complaint, El Toro security guards formerly assigned to guard Citibank premises loitered around the bank's premises in large groups and threatened to stage a strike, which would hamper its operations and the normal conduct of its business and that the bank would suffer damages should a strike push through. On the basis of the allegations of the complaint, it is safe to conclude that the dispute involved is a civil one, not a labor dispute. Consequently, we rule that jurisdiction over the subject matter of the complaint lies with the regional trial court.
