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    ART. 218 Citibank Vs CA

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    Juan Doe
    1. Citibank filed a complaint against CIGLA, a labor union representing security guards, for an injunction and damages. 2. CIGLA claimed the case involved a labor dispute between Citibank and the security guards. However, Citibank argued there was no employer-employee relationship with the guards, who were employees of an independent security agency, El Toro. 3. The Supreme Court ruled that no labor dispute existed because El Toro was an independent contractor of Citibank, so there was no employer-employee relationship between Citibank and the security guards. Therefore, the regional trial court had jurisdiction over the civil dispute, not labor authorities.

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    ART. 218 Citibank Vs CA

    Uploaded by

    Juan Doe
    111 views2 pages
    1. Citibank filed a complaint against CIGLA, a labor union representing security guards, for an injunction and damages. 2. CIGLA claimed the case involved a labor dispute between Citibank and the security guards. However, Citibank argued there was no employer-employee relationship with the guards, who were employees of an independent security agency, El Toro. 3. The Supreme Court ruled that no labor dispute existed because El Toro was an independent contractor of Citibank, so there was no employer-employee relationship between Citibank and the security guards. Therefore, the regional trial court had jurisdiction over the civil dispute, not labor authorities.

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    ART. 218 Citibank vs CA

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    1. Citibank filed a complaint against CIGLA, a labor union representing security guards, for an injunction and damages. 2. CIGLA claimed the case involved a labor dispute between Citibank and the security guards. However, Citibank argued there was no employer-employee relationship with the guards, who were employees of an independent security agency, El Toro. 3. The Supreme Court ruled that no labor dispute existed because El Toro was an independent contractor of Citibank, so there was no employer-employee relationship between Citibank and the security guards. Therefore, the regional trial court had jurisdiction over the civil dispute, not labor authorities.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    111 views2 pages

    ART. 218 Citibank Vs CA

    Uploaded by

    Juan Doe
    1. Citibank filed a complaint against CIGLA, a labor union representing security guards, for an injunction and damages. 2. CIGLA claimed the case involved a labor dispute between Citibank and the security guards. However, Citibank argued there was no employer-employee relationship with the guards, who were employees of an independent security agency, El Toro. 3. The Supreme Court ruled that no labor dispute existed because El Toro was an independent contractor of Citibank, so there was no employer-employee relationship between Citibank and the security guards. Therefore, the regional trial court had jurisdiction over the civil dispute, not labor authorities.

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    © All Rights Reserved
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    1. Case Title: Citibank vs.

    CA
    GR No: 108961 Date: Nov 27, 1998

    Ponente: Pardo, J.

    Doctrine: 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."

    FACTS: Citibank and El Toro Security Agency, Inc. (hereafter El Toro) entered into a contract
    for the latter to provide security and protective services to safeguard and protect the bank's
    premises.

    Under the contract, El Toro obligated itself to provide the services of security guards to
    safeguard and protect the premises and property 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. Citibank renewed the security contract with El Toro yearly until
    it expired. Then, Citibank Integrated Guards Labor Alliance-SEGA-TUPAS/FSM (hereafter
    CIGLA) filed with the National Conciliation and Mediation Board(NCMB) a request for
    preventive mediation based on Unfair labor practice; Dismissal of union officers/members; and
    Union busting.

    CIGLA converted its request for preventive mediation into a notice of strike for failure of the
    parties to reach a mutually acceptable settlement of the issues, which it followed with a
    supplemental notice of strike alleging as supplemental issue the mass dismissal of all union
    officers and members. Citibank
    filed with the Regional Trial Court, Makati, a complaint for injunction and damages. CIGLA
    filed with the trial court a motion to dismiss the complaint. The motion alleged that:

    a) The Court had no jurisdiction, this being labor dispute.

    b) The guards were employees of the bank.

    c) There were pending cases/labor disputes between the guards and the bank at the different
    agencies of the Department of Labor and Employment (DOLE).

    d) The bank was guilty of forum shopping in filing the complaint with the Regional Trial Court
    after submitting itself voluntarily to the jurisdiction of the different agencies of the DOLE.
    LA/RTC/NLRC RULING: Trial court denied respondent CIGLA's motion to dismiss

    CA RULING: Court of Appeals promulgated its decision in CIGLA's favor

    APPEAL TO THE SC:

    Petitioner's Contention: 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.

    Respondent's Contention:
    There is EE-ER relationship between Citibank and the security guards

    ISSUE/S: WON the case involves a labor dispute? (Is there a labor dispute between Citibank
    and the security guards, members of respondent CIGLA, regardless of whether they stand in the
    relation of employer and employees?)

    HELD: No. Article 212, paragraph l 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."

    El Toro was an independent contractor. Thus, no EE-ER 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. The dispute involved is
    a civil one and the jurisdiction over the subject matter of the complaint lies with the regional trial
    court.

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