Jurisdiction of National Labor Relations Commission

On April 4, 2011, petitioner Comscentre Phils. Inc., hired respondent Camille B. Rocio as a network engineer. On Aug. 5, 2011, respondent informed petitioner of her intention to resign effective Sept. 9, 2011. Petitioner informed respondent she had to pay an “employment bond” of P80,000 for resigning within 24 months from the time she got employed as provided in her employment contract.

The following day, petitioner issued a showcause letter seeking respondent’s explanation why she should not be subjected to disciplinary action for raising her concerns directly to its Australian human resource manager and going around her colleagues to discuss about her resignation. She was immediately placed on a preventive suspension. Thus, on Sept. 16, 2011, respondent filed a complaint against petitioner for illegal suspension and money claims.

The Court of Appeals (CA) nullified the directive of the National Labor Relations Commission (NLRC) to deduct the P80,000 “employment bond” from the total monetary award due to respondent. It ruled that petitioner’s claim for payment of employment bond is within the exclusive jurisdiction of regular courts.

Did the CA err? Ruling: Yes.

In Bañez v. Valdevilla, 387 Phil. 601, 607-608 (2000), the Court elucidated that the jurisdiction of labor tribunals is comprehensive enough to include claims for all forms of damages “arising from the employer-employee relations.” Thus, the Court decreed therein that labor tribunals have jurisdiction to award not only the reliefs provided by labor laws, but also damages governed by the Civil Code.

Further, in Supra Multi-Services Inc. v. Labitigan, 792 Phil. 336, 368-369 (2016), while we recognized that Article 224 of the Labor Code had been invariably applied to claims for damages filed by an employee against the employer, we held that the law should also apply with equal force to an employer’s claim for damages against its dismissed employee, provided that the claim arises from or is necessarily connected with the fact of termination and should be entered as a counterclaim in the illegal dismissal case. Thus, the “reasonable” causal connection with the employer-employee relationship” is a requirement not only in employees’ money claims against the employer but is, likewise, a condition when the claimant is the employer.

Here, the controversy was rooted in respondent’s resignation from the company within 24 months from the time she got employed in violation of the “Minimum Employment Length” clause of her employment contract. When respondent informed petitioners of her intention to resign merely five months after she got hired, they reminded respondent of her obligation to pay the “employment bond” of P80,000 as indemnity for the expenses the company incurred in her training as network engineer. This prompted respondent to seek clarification by e-mail from Comscentre’s Australian human resource manager Lianne Glass. But as it was, petitioners found respondent’s act of directly addressing her query to manager Glass to be in violation of company directives. For this supposed infraction, she was suspended until Sept. 9, 2011, the date her resignation was to take effect. Consequently, respondent sued petitioners for illegal suspension and money claims before the labor arbiter. Petitioners, in turn, pursued their claim for payment of “employment bond” in the same proceedings.

It is clear that petitioners’ claim for payment is inseparably intertwined with the parties’ employer-employee relationship. For it was respondent’s act of prematurely severing her employment with the company which gave rise to the latter’s cause of action for payment of “employment bond.” As aptly found by the NLRC, petitioners’ claim was “an offshoot of the resignation of (respondent) and the complications arising therefrom and which eventually led to the filing of the case before the Labor Arbiter.” Verily, petitioners’ claim falls within the original and exclusive jurisdiction of the labor tribunals.

On this score, we further sustain the NLRC’s finding that respondent is liable for payment of “employment bond” pursuant to her undertaking in the employment contract. She herself has not disputed this liability arising as it did from her breach of the minimum employment period clause. Notably, she committed to abide thereby in exchange for the expenses incurred by the company for her training as network engineer. (Comscentre Phils. Inc. and Patrick Boe vs. Camille B. Rocio, G.R. 222212, Jan. 22, 2020).

As aptly found by the National Labor Relations Commission, petitioners’ claim was “an offshoot of the resignation of (respondent) and the complications arising therefrom and which eventually led to the filing of the case before the Labor Arbiter.” Verily, petitioners’ claim falls within the original and exclusive jurisdiction of the labor tribunals