14 Banez Vs Valdevilla

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BEBIANO M.

BAEZ, petitioner,

vs.
HON. DOWNEY C.
VALDEVILLA and ORO MARKETING, INC., respondents
G.R. No. 128024. May 9, 2000.
GONZAGA-REYES, J. :
p

Facts:
Petitioner was the sales operations manager of private respondent in its branch in Iligan City. In
1993, private respondent "indenitely suspended" petitioner and the latter led a complaint for
illegal dismissal with the National Labor Relations Commission ("NLRC") in Iligan City. In a
decision dated July 7, 1994, Labor Arbiter Nicodemus G. Palangan found petitioner to have been
illegally dismissed and ordered the payment of separation pay in lieu of reinstatement, and of
back wages and attorney's fees. The decision was appealed to the NLRC, which dismissed the
same for having been led out of time. Elevated by petition for certiorari before this Court, the
case was dismissed on technical grounds; however, the Court also pointed out that even if all the
procedural requirements for the ling of the petition were met, it would still be dismissed for
failure to show grave abuse of discretion on the part of the NLRC.
On November 13, 1995, private respondent led a complaint for damages before the Regional
Trial Court ("RTC") of Misamis Oriental. Private respondents are claiming damages because of
the ruling by the NLRC.
Issue:
Whether or not the NLRC is without original, exclusive jurisdiction even over issues regarding
claims for damages arising from an employee-employer relations.
Ruling:
Art. 217(a) of the Labor Code bestows upon the Labor Arbiter original and exclusive jurisdiction
over ALL claims for damages arising from employer-employee relations. This means the Labor
Arbiter has jurisdiction to award not only the reliefs provided by labor laws, but also damages
governed by the Civil Code. This includes the claim of an employer for actual damages against
its dismissed employee, where the basis for the claim is necessarily connected with the fact of
termination. Hence, the claim should have been entered as a counterclaim in the illegal dismissal
case and not subject of a separate action for damages. Appeal from the Labor Arbiter's decision
should have been the proper remedy, but the same is no longer available with the nality of the
decision of the NLRC. The petition was granted, and the complaint before the trial court against
petitioner was dismissed.

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