Nestlé Philippines, Inc. vs. NLRC

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Nestlé Philippines, Inc. vs.

NLRC
G.R. No. 85197. March 18, 1991
Facts:
Private respondents were employed by the petitioner and they availed of the
company’s car loan policy. The company purchased the cars to be paid back by the
employees through monthly deductions from their salaries. The company retains
ownership of the vehicles until fully paid.
Private respondents were dismissed from the service for having participated in
an illegal strike and for certain irregularities. Thus, they filed complaints for illegal
dismissal in the Arbitration Branch of the NLRC. The Labor Arbiter dismissed their
complaints. Pending appeal from NLRC, private respondents had been directed to
either settle the remaining balance of the cost of their respective cars, or return them
to the company for proper disposition.
As they failed and refused to avail of either option, the company filed in the
Regional Trial Court of Makati a civil suit to recover possession of the cars. The Court
issued an Order dated March 7, 1988 directing the Deputy Sheriff to take the motor
vehicles into his custody.
The private respondents sought a temporary restraining order in the NLRC to
stop the company from cancelling their car loans and collecting their monthly
amortizations pending the final resolution of their appeals in the illegal dismissal case.
The NLRC en banc, issued a resolution granting their petition for injunction.

Issue:
Whether or not NLRC acted with grave abuse of discretion amounting to lack of
jurisdiction when it issued a labor injunction without legal basis and in the absence of
any labor dispute related to the same.

Held:
Nestlé’s demand for payment of the private respondents’ amortizations on their
car loans, or, in the alternative, the return of the cars to the company, is not a labor,
but a civil, dispute. It involves debtor-creditor relations, rather than employee-
employer relations. x x x The NLRC gravely abused its discretion and exceeded its
jurisdiction by issuing the writ of injunction to stop the company from enforcing the
civil obligation of the private respondents under the car loan agreements and from
protecting its interest in the cars which, by the terms of those agreements, belong to it
(the company) until their purchase price shall have been fully paid by the employee.
The terms of the car loan agreements are not in issue in the labor case. The rights and
obligations of the parties under those contracts may be enforced by a separate civil
action in the regular courts, not in the NLRC.

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