Nestle vs. NLRC - Digest

Nestlé Philippines, Inc. vs. NLRC complaints and upheld the legality of their dismissal.
complaints and upheld the legality of their dismissal. They appealed to the NLRC where
their appeals are still pending.
LABOR INJUNCTION (Issuing Agency)
In the Notices of Dismissal which they received from Nestlé, the private respondents had
The power of the NLRC to enjoin or restrain the commission of any or all prohibited or been directed to either settle the remaining balance of the cost of their respective cars, or
unlawful acts as provided in Art. 218 of the Labor Code, can only be exercised in a labor return them to the company for proper disposition.
dispute.
As they failed and refused to avail of either option, the company filed in the Regional Trial
NESTLÉ PHILIPPINES, INC., petitioner, vs. NATIONAL LABOR RELATIONS Court of Makati a civil suit to recover possession of the cars. The Court issued an Order
COMMISSION, EUGENIA C. NUNEZ, LIZA T. VILLANUEVA, EMMANUEL S. directing the Deputy Sheriff to take the motor vehicles into his custody.
VILLENA, RUDOLPH C. ARMAS, RODOLFO M. KUA and RODOLFO A.
SOLIDUM, respondents. The private respondents sought a temporary restraining order in the NLRC to stop the
company from cancelling their car loans and collecting their monthly amortizations
195 SCRA 340 | G.R. No. 85197 pending the final resolution of their appeals in the illegal dismissal case which was granted
March 18, 1991 by the NLRC en banc. The company filed a motion for reconsideration, but it was denied
Ponente: GRIÑO-AQUINO, J. for tardiness. Hence, this petition for certiorari alleging that the NLRC acted with grave
abuse of discretion amounting to lack of jurisdiction when it issued a labor injunction
without legal basis and in the absence of any labor dispute related to the same.
NATURE OF CASE
The private respondents, in their comment on the petition, alleged that there is a labor
PETITION for certiorari to review the resolutions of the National Labor Relations dispute between the petitioner and the private respondents and that their default in paying
Commission. the amortizations for their cars was brought about by their illegal dismissal from work by
the petitioner as punishment for their participation in the illegal strike.
BRIEF
ISSUE/s of the CASE
This petition for certiorari seeks a review of the resolutions dated May 28, 1988 and
September 1, 1988 of the National Labor Relations Commission (NLRC) in Injunction Whether NLRC gravely abused its discretion and exceeded its jurisdiction by issuing the
Case No. 1582 granting the injunction prayed for by the private respondents, to hold in writ of injunction
abeyance the cancellation of their car loans and payments of the monthly amortizations
thereon pending the resolution of their complaints for illegal dismissal. ACTION/S OF THE COURT
FACTS NLRC: Granted the petition for injunction

SC: The questioned resolution of the NLRC in Injunction is hereby annulled and set aside.
The private respondents were employed by the petitioner either as sales representatives or
medical representatives. By reason of the nature of their work they were each allowed to COURT RATIONALE ON THE ABOVE CASE
avail of the company’s car loan policy where the company advances the purchase price of a
car to be paid back by the employee through monthly deductions from his salary, the Nestlé’s demand for payment of the private respondents’ amortizations on their car loans,
company retaining the ownership of the motor vehicle until it shall have been fully paid for. or, in the alternative, the return of the cars to the company, is not a labor, but a civil,
All of the private respondents availed of the petitioner’s car loan policy. dispute. It involves debtor-creditor relations, rather than employee-employer relations. The
NLRC gravely abused its discretion and exceeded its jurisdiction by issuing the writ of
Private respondents Nuñez, Villanueva, Villena and Armas were dismissed from the injunction to stop the company from enforcing the civil obligation of the private
service for having participated in an illegal strike. Respondents Kua and Solidum were also respondents under the car loan agreements and from protecting its interest in the cars which,
dismissed for certain irregularities. All the private respondents filed complaints for illegal by the terms of those agreements, belong to it (the company) until their purchase price shall
dismissal in the Arbitration Branch of the NLRC. The Labor Arbiter dismissed their have been fully paid by the employee. The terms of the car loan agreements are not in issue
in the labor case. The rights and obligations of the parties under those contracts may be
enforced by a separate civil action in the regular courts, not in the NLRC.
The power of the NLRC to issue writs of injunction is found in Article 218 of the Labor
Code, which provides:
“Art. 218. Powers of the Commission.—The Commission shall have the power and authority:
“xxx xxx xxx.
“(e) To enjoin or restrain any actual or threatened commission of any or all prohibited or unlawful
acts or to require the performance of a particular act in any labor dispute which, if not restrained or
performed forthwith, may cause grave or irreparable damage to any party or render ineffectual any
decision in favor of such party: x x x.”
That power, as the statute provides, can only be exercised in a labor dispute. Paragraph (1)
of Article 212 of the Labor Code defines a labor dispute as follows:
“(1) ‘Labor dispute’ includes any controversy or matters 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 Nestlé Philippines, Inc., correctly pointed out that:

“The twin directives contained in petitioner’s letters to the private respondents to either (1) settle the
remaining balance on the value of their assigned cars under the company car plan or return the cars to
the company for proper disposition; or (2) to pay all outstanding accountabilities to the company—
are matters related to the enforcement of a civil obligation founded on contract. It is not dependent on
or related to any labor aspect under which a labor injunction can be issued. Whether or not the private
respondents remain as employees of the petitioner, there is no escape from their obligation to pay
their outstanding accountabilities to the petitioner; and if they cannot afford it, to return the cars
assigned to them.
“As noted, the options given to the private respondents are civil in nature arising from contractual
obligations. There is no labor aspect involved in the enforcement of those obligations.”
SUPREME COURT RULING
WHEREFORE, the petition for certiorari is granted. The questioned resolution dated May
27, 1988 of the NLRC in Injunction Case No. 1582 (Annex A) is hereby annulled and set
aside. Costs against the private respondents.
SO ORDERED.

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Nestlé Philippines, Inc. vs. NLRC complaints and upheld the legality of their dismissal.

FACTS NLRC: Granted the petition for injunction

Petitioner Nestlé Philippines, Inc., correctly pointed out that:

SUPREME COURT RULING

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