Jurisdiction of regular courts

Dear PAO,

I own a small tindahan (store). My tindera (helper) came to my house, and I loaned her P10,000 because she had to take her child to the hospital. She still refused to return the said amount until now, so I filed a case against her with the National Labor Relations Commission (NLRC). Was my case filed correctly with the NLRC?

Leticia

Dear Leticia,

The answer to your question can be found in the case titled «Georg Grotjahn GMBH & Co. v. Hon. Lucia Violago Isnani, Presiding Judge, Regional Trial Court, Makati, Br. 59, et al.», docketed as GR 109272, dated Aug. 10, 1994, and penned by Chief Justice Reynato Puno, to wit:

«In San Miguel Corporation vs. NLRC, 161 SCRA 719 (1988), we crystallized the doctrines set forth in the Medina, Singapore Airlines, and Molave Motors cases, thus:

»… The important principle that runs through these three (3) cases is that where the claim to the principal 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 to the Labor Arbiter and the NLRC. In such situations, resolutions of the dispute require expertise, not in labor management relations nor in wage structures and other terms and conditions of employment, but rather in the application of the general civil law. Clearly, such claims fall outside the area of competence or expertise ordinarily ascribed to Labor Arbiters and the NLRC and the rationale for granting jurisdiction over such claims to these agencies disappears.

«Civil Case No. 92-2486 is a simple collection of a sum of money brought by petitioner, as creditor, against private respondent Romana Lanchinebre, as debtor. The fact that they were employer and employee at the time of the transaction does not negate the civil jurisdiction of the trial court. The case does not involve of a labor dispute but recovery of a sum of money based on our civil laws on obligation and contract.» (Emphasis added)

Based on the facts you provided, your case may be considered a simple collection of a sum of money brought by you as a creditor against