BUENAFLOR v. RAMIREZ, JR.

HON. CESAR D. BUENAFLOR v. JOSE R. RAMIREZ, Jr.
G.R. No. 201607
February 15, 2017


FACTS:

Chairman Eufemio Domingo of the Presidential Anti-Graft Commission (PAGC) appointed respondent Jose R. Ramirez, Jr. as Executive Assistant III and concurrently designated him as Assistant Accountant. On September 28, 2001, Chairman Domingo resigned,and petitioner Cesar D. Buenaflor succeeded him. The petitioner terminated Ramirez as of the same date as Chairman Eugenio's resignation on the ground that his tenure had expired by virtue of the position of Executive Assistant being personal and confidential, and, hence, co-terminous with that of the appointing authority.

Believing that his appointment had been contractual in nature, Ramirez sued in the RTC to declare his dismissal null and void. The RTC rendered judgment declaring Buenaflor guilty of unlawful termination because he had not discharged his burden of proving that Ramirez's employment was coterminous with that of Chairman Domingo, and ruling in favor of Ramirez.

Buenaflor seasonably filed his motion for reconsideration and later on was denied. Buenaflor assailed the order of the RTC by petition for certiorari in the CA, alleging that the RTC thereby gravely abused its discretion amounting to lack or excess of jurisdiction. Buenaflor moved for reconsideration, but the CA denied his motion for reconsideration.


ISSUES:

1. Court of Appeals, in arriving its decision and resolution, decided the case in accordance with law and existing jurisprudence?

2. Court of Appeals committed grave abused of discretion in not declaring that the RTC has no jurisdiction to hear and decide the instant civil service related case, which is under the sole jurisdiction of the CSC?


RULING:

1. The jurisdiction of a court over the subject matter of a particular action is determined by the plaintiffs allegations in the complaint and the principal relief he seeks in the light of the law that apportions the jurisdiction of courts.

2. It is clarified that the CSC has jurisdiction over a case involving a civil servant if it can be regarded as equivalent to a labor dispute resoluble under the Labor Code; conversely, the regular court has jurisdiction if the case can be decided under the general laws, such as when the case is for the recovery of private debts, or for the recovery of damages due to slanderous remarks of the employer, or for malicious prosecution of the employees.