Laureano v. CA
G.R. No. 114776. February 2, 2000

Facts: 

In 1979, Laureano was employed with Singapore Airlines Limited for a 5-year contract. However, in 1982, Singapore Airlines was hit by a recession. Thus, Singapore Airlines initiated cost-cutting measures such as terminating its A-300 pilots including Laureano. Plaintiff filed a case for illegal dismissal against Singapore Airlines, but later on withdrew the complaint. Thereafter, Laureano filed the instant case for damages due to illegal termination of contract of services. 

Singapore Airlines filed a motion to dismiss alleging inter alia: (1) that the court has no jurisdiction over the subject matter of the case, and (2) that Philippine courts have no jurisdiction over the case. It contended that the complaint is for illegal dismissal together with a money claim arising out of and in  the  course  of  plaintiff’s  employment  "thus  it  is  the  Labor  Arbiter  and  the  NLRC  who  have  the  jurisdiction pursuant to Article 217 of the Labor Code" and that, since plaintiff was employed in Singapore, all other aspects of his employment contract and/or documents executed in Singapore. Thus, defendant company postulates that Singapore laws should apply and courts thereat shall have jurisdiction.

Laureano countered that: (1) where the items demanded in a complaint are the natural consequences flowing from a breach of an obligation and not labor benefits, the case is intrinsically a civil dispute; (2) the case involves a question that is beyond the field of specialization of labor arbiters; and (3) if the complaint is grounded not on the employee's dismissal per se but on the manner of said dismissal and the consequence thereof, the case falls under the jurisdiction of the civil courts. The RTC denied the motion to dismiss. Subsequently, it rendered a decision in favor of Laureano. The CA reversed the decision.


Issue: 

Whether or not Singaporean Laws should be applied in the case


Held: 

The trial court rightly ruled on the application of Philippine law, thus:

Neither can the Court determine whether the termination of the plaintiff is legal under the Singapore Laws because of the defendant's failure to show which specific laws of Singapore Laws apply to this case. As substantially discussed in the preceding paragraphs, the Philippine Courts do not take judicial notice of the laws of Singapore. The defendant that claims the applicability of the Singapore Laws to this case has the burden of proof. The defendant has failed to do so. Therefore, the Philippine law should be applied.

The SC, however, affirmed the decision of the CA. It held that Laureano's termination from employment was for an authorized cause, for which he was given ample notice and opportunity to be heard. The SC agreed that because of the world-wide recession of the airline industry, the defendant company had no choice but to adopt cost cutting measures such as cutting down services, number of frequencies of flights, and reduction of the number of flying points. As a result, defendant company had to lay off A-300 pilots, including plaintiff-appellee, which it found to be in excess of what is reasonably needed.