San Mig v. NLRC G.R.

80774, May 31, 1988

FACTS:

San Miguel Corporation sponsored an innovation program under which, the management undertook to grant
cash awards to all SMC employees except higher-ranked personnel who submitted to the corporation ideas and
suggestions found to be beneficial to the corporation.

Rustico Vega then submitted a proposal but was not accepted. Vega filed a complaint against the company
with the Regional Arbitration Branch no. VII, contending that he should be paid 60,000 pesos since his idea was
implemented by the company.

San Miguel Corp., in their answer stated that they turned down the proposal of Vega for lack of originality.

The Labor Arbiter dismissed the complaint on the ground that the money claim is not a necessary incident of
his employment.

Upon appeal of Vega to the NLRC, it ordered San Miguel Corp to pay Vega the 60,000 pesos. San Miguel Corp then
sought to annul the judgment on the ground that the Labor Arbiter and the NLRC have no jurisdiction over the
case.

ISSUE:

Whether or not the Labor Arbiter and the NLRC has jurisdiction over the case.

RULING:

No, just because the claim arises from employer-employee relationship, it does not follow that it is
automatically within the jurisdiction of the Labor Arbiter or the NLRC.

The company’s undertaking, though unilateral in origin, could nonetheless ripen into an enforceable
contractual obligation (facio ut des) obligation on the part of San Miguel Corp. Under certain circumstances. This,
whether or not an enforceable contract, albeit implied arid innominate, had arisen between petitioner corporation
and private respondent Vega in the circumstances of the case, and if so, whether or not it had been breached, are
preeminently legal questions, questions not to be resolved by referring to labor legislation and having nothing to
do with wages or other terms and conditions of employment, but rather having recourse to our law on contracts.

If the relief sought is to be resolved not by reference to the Labor Code or other labor relations statute or a
collective bargaining agreement but by the general civil law, the jurisdiction over the dispute belongs to the regular
courts of justice and not the the Labor Arbiter and the NLRC. In such situations, resolution of the dispute requires
expertise, not in labor management relations nor in wage structures and other terms and conditions of payment,
but rather in the application of the general civil law.