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COCA COLA BOTTLERS v. JOSE S. ROQUE

FACTS:

Coca-Cola Bottlers Phils., Inc. (Coke Bottlers) hired respondent Jose Roque in 1971 as a route helper. In 1980, he was promoted to acting salesman. However, in June 1982, Coke Bottlers reassign Roque back to his former position as a route helper due to the accumulation of unremitted collections, which Roque denied. Supervisor Henson initiated an administrative investigation against Roque without giving him an opportunity to be heard or represented by counsel. Consequently, in October 1982, Coke Bottlers summarily dismissed Roque.

On March 23, 1983, Supervisor Henson filed a criminal case for estafa against Roque with the City Fiscal, Cabanatuan City. During the preliminary investigation, Roque was unable to present evidence as he did not receive the notices from the fiscal due to the wrong address.

On August 26, 1983, the City Fiscal filed an information against Roque for estafa with the Regional Trial Court, Cabanatuan City. After trial, the court acquitted Roque of the crime charged.

In June 1989, Roque filed a complaint for damages against Coke Bottlers. He alleged that during the seven years the estafa case was being tried, he and his family suffered severely and were pushed to the brink of poverty, causing them embarrassment and humiliation.

The trial court ruled in favor of Roque, ordering Coke Bottlers to pay him various amounts as actual or compensatory damages, moral damages, exemplary damages, and attorney's fees. Coke Bottlers filed a motion for reconsideration, which was denied. They then appealed to the Court of Appeals.

While the appeal was pending, a writ of execution pending appeal was partially enforced, and Roque received the sum of P506,500.00 as actual and compensatory damages.

The Court of Appeals later rendered a decision reducing the amount of damages awarded to Roque. Both parties filed motions for reconsideration, which were denied.

Hence, this petition for review before the Supreme Court. Petitioners raised various issues, including the court's jurisdiction over the case, denial of due process, awarding damages for malicious prosecution, lack of legal or evidentiary basis for actual damages, and the grant of execution pending appeal.

ISSUES:

  1. Whether or not the Regional Trial Court, Nueva Ecija, has jurisdiction over the case considering that the complaint is in the nature of a claim for damages arising from and by virtue of an employer-employee relationship;

  2. Whether or not the petitioners were denied their right to due process of law;

  3. Whether or not the lower court erred in awarding damages for malicious prosecution;

  4. Whether or not the lower court erred in awarding actual damages considering the same has no legal or evidentiary basis;

  5. Whether or not the lower court erred in granting respondent's motion of execution pending appeal.

RULING:

  1. The Regional Trial Court has jurisdiction over the case. The claim for damages is not purely an employer-employee relation matter but involves other elements such as malicious prosecution and violation of due process. These issues fall within the jurisdiction of the regular courts and are not exclusively within the jurisdiction of the labor arbiter under the Labor Code.

  2. The petitioners were not denied their right to due process of law. The Court found that the respondent was given an opportunity to be heard during the administrative investigation and during the preliminary investigation of the estafa case. There was no violation of due process on the part of the petitioners.

  3. The lower court did not err in awarding damages for malicious prosecution. The evidence presented during the trial showed that the petitioners initiated a criminal case against the respondent without sufficient evidence to support the charges. The court ruled that the petitioners were liable for damages for malicious prosecution.

  4. The lower court did not err in awarding actual damages. The court found that there was sufficient basis for awarding actual damages, including salary and retirement benefits unlawfully withheld from the respondent. The evidence presented during the trial supported the award of actual damages.

  5. The lower court did not err in granting the respondent's motion for execution pending appeal. The court found that the respondent had a valid and enforceable judgment and that there were no valid grounds to stay the execution of the judgment.

PRINCIPLES:

  • Claims for damages arising from an employer-employee relationship are not exclusively within the jurisdiction of the labor arbiter but may also fall within the jurisdiction of the regular courts if other issues such as malicious prosecution and violation of due process are involved.

  • Due process requires that the parties be given an opportunity to be heard and present evidence during administrative investigations and preliminary investigations.

  • Damages may be awarded for malicious prosecution if it is proven that a criminal case was initiated without sufficient evidence.

  • Actual damages may be awarded if there is sufficient evidence to support the claim, including salary and retirement benefits unlawfully withheld.

  • Execution pending appeal may be granted if there is a valid and enforceable judgment and there are no valid grounds to stay the execution.