Eviota vs. CA

EDUARDO G. EVIOTA vs. THE HON.
COURT OF APPEALS
FACTS:
Respondent is a foreign banking institution authorized to do business in the Philippines. While defendant
Eduardo Eviota (Eviota) is a former employee of the Bank. Eviota began negotiating with the Bank on his
possible employment with the latter. The Bank made sure that Eviota was fully aware of all the terms and
conditions of his possible job with the Bank. Eviota indicated his conformity with the Banks Offer of
Employment by signing a written copy of such offer. Eviota assumed his position as Compensation and
Benefits Manager with the Bank and began to discharge his duties. After leading the Bank to believe that
he had come to stay, Eviota suddenly resigned his employment with immediate effect to re-join his
previous employer. His resignation did not comply with the 30-day prior notice rule under the law and
under the Employment Contract. Aside from causing no small degree of chaos within the Bank by reason
of his sudden resignation, Eviota made off with a computer diskette and other papers and documents
containing confidential information on employee compensation and other Bank matters. With the benefit
of hindsight, the Bank realizes that it was simply used by Eviota as a mere leverage for his selfish efforts
at negotiating better terms of employment with his previous employer. The Bank made a written demand
on Eviota to return the aforementioned computer diskette and other confidential documents and papers,
reimburse the Bank for the various expenses incurred on his account as a result of his resignation (with
legal interest), and pay damages. Eviota never complied with the Banks demand that he reimburse the
latter for the other expenses incurred on his account. This prompted Respondent bank filed a complaint
against the petitioner with the RTC.
The petitioner, on the other hand, filed a motion to dismiss the complaint on the ground that the action
for damages of the respondent bank was within the exclusive jurisdiction of the Labor Arbiter under
paragraph 4, Article 217 of the Labor Code of the Philippines, as amended. The petitioner averred that the
respondent banks claim for damages arose out of or were in connection with his employer-employee
relationship with the respondent bank or some aspect or incident of such relationship. The respondent
bank opposed the motion, claiming that its action for damages was within the exclusive jurisdiction of the
trial court. Although its claims for damages incidentally involved an employer-employee relationship, the
said claims are actually predicated on the petitioner’s acts and omissions which are separately, specifically
and distinctly governed by the New Civil Code.
Hence, this petition.
ISSUE:
WON the action filed is within the jurisdiction of the Labor Arbiter or the regular courts.
HELD:
Not every controversy or money claim by an employee against the employer or vice-versa is within the
exclusive jurisdiction of the labor arbiter. A money claim by a worker against the employer or vice-versa
is within the exclusive jurisdiction of the labor arbiter only if there is a reasonable causal connection
between the claim asserted and employee-employer relation. Absent such a link, the complaint will be
cognizable by the regular courts of justice.
Actions between employees and employer where the employer-employee relationship is merely
incidental and the cause of action precedes from a different source of obligation is within the exclusive
jurisdiction of the regular court.
On appeal to the higher court, it held that jurisdiction over the controversy belongs to the civil courts. It
stated that the action was for breach of a contractual obligation, which is intrinsically a civil dispute. It
further stated that while seemingly the cause of action arose from employer-employee relations, the
employers claim for damages is grounded on wanton failure and refusal without just cause to report to
duty coupled with the averment that the employee maliciously and with bad faith violated the terms and
conditions of the contract to the damage of the employer. Such averments removed the controversy from
the coverage of the Labor Code of the Philippines and brought it within the purview of the Civil Law.
Jurisprudence has evolved the rule that claims for damages under paragraph 4 of Article 217, to be
cognizable by the Labor Arbiter, must have a reasonable causal connection with any of the claims provided
for in that article. Only if there is such a connection with the other claims can the claim for damages be
considered as arising from employer-employee relations.
It is evident that the causes of action of the private respondent against the petitioner do not involve the
provisions of the Labor Code of the Philippines and other labor laws but the New Civil Code. Thus, the said
causes of action are intrinsically civil. There is no causal relationship between the causes of action of the
private respondent’s causes of action against the petitioner and their employer-employee
relationship. The fact that the private respondent was the erstwhile employer of the petitioner under an
existing employment contract before the latter abandoned his employment is merely incidental.

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EDUARDO G. EVIOTA vs. THE HON.

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