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UNIVERSAL AQUARIUS v. Q.C. HUMAN RESOURCES MANAGEMENT CORPORATION

FACTS:

Universal Aquarius, Inc. (Universal) and Conchita Tan (Tan) are engaged in the manufacturing, trading, delivery, and distribution of chemical products. They filed a complaint against strikers led by Rodolfo Capocyan and Q.C. Human Resources Management Corporation (Resources) for the disruption of their business operations. The strikers picketed and obstructed Universal's chemical plant, as well as intercepted their delivery trucks. Universal and Tan entered into an agreement with the strikers to resolve the labor dispute and subsequently filed a notice of dismissal against them. Resources filed a motion to dismiss, arguing that they should not be held liable. The trial court denied the motion, but the Court of Appeals (CA) set it aside and dismissed the complaint for lack of cause of action. The CA reasoned that while the right of Universal and Tan to operate their businesses was violated during the strike, the agreement to end the dispute removed their cause of action against Resources.

ISSUES:

  1. Whether or not the complaint stated a cause of action against Resources.

  2. Whether or not the cause of action of the plaintiffs was lost upon dismissal of the case against the individual defendants.

  3. Whether or not the RTC had jurisdiction over the case.

RULING:

  1. The Court of Appeals (CA) held that the complaint failed to state a cause of action against Resources. It ruled that the right of the plaintiffs to operate their business was violated by the strike staged by Rodolfo Capocyan and others, and that Resources was only made defendant in the complaint because it was the employer of the strikers.

  2. The CA concluded that the cause of action of the plaintiffs was extinguished when Universal Aquarius agreed to end the dispute by providing financial assistance to Obrero Pilipino, resulting in the dismissal of the case against the strikers.

  3. The CA further held that since the complaint failed to state a cause of action against Resources, the RTC lacked jurisdiction over the case.

PRINCIPLES:

  • A complaint must contain a concise statement of the ultimate facts constituting the plaintiff's cause of action. Failure to do so would result in the dismissal of the complaint for lack of cause of action.

  • A cause of action may be extinguished or lost when subsequent events occur that effectively resolve or settle the dispute between the parties.

  • The jurisdiction of a court is determined by the allegations and reliefs sought in the complaint. If the complaint fails to state a cause of action within the court's jurisdiction, the court lacks jurisdiction over the case.