Facts:

The case revolves around Marilyn B. Asentista, the petitioner, who was employed by JUPP & Company, Inc. (JUPP) as a sales secretary starting April 16, 2007. She later transitioned to a regular employee as a sales assistant on March 14, 2008, and was appointed as a sales agent in July 2010. As a sales agent, she received a commission of two percent for reaching her monthly sales quota. Despite achieving her quotas, JUPP failed to pay her earned sales commissions, prompting Asentista to repeatedly request payment. In 2011, JUPP awarded her a Toyota Avanza vehicle as recognition of her sales performance, but the ownership remained with the company. JUPP began to deduct payments related to the vehicle from her unpaid commissions - specifically a P113,000 deduction for car plan participation and a P68,721.36 rental fee while she utilized the vehicle for both personal and official purposes. Asentista resigned effective February 28, 2013, and subsequently filed a claim for the comm

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Facts:

Employment and Commission Arrangement

• Marilyn B. Asentista was initially employed by JUPP on April 16, 2007, as a sales secretary and later became a regular employee on March 14, 2008.
• In July 2010, she was promoted and appointed as a sales agent for the Northern Mindanao area, whereby she became entitled to earn a two-percent commission on every attained monthly sales quota.

Non-Payment of Earned Commission

• Despite meeting her monthly sales targets, Asentista repeatedly failed to receive her earned sales commission from JUPP.
• The unpaid commission issue became a central grievance, leading Asentista to seek legal redress.

Car Plan Involvement and Unauthorized Deductions

• In 2011, JUPP, through its Administrative and Finance Officer, issued Asentista a Toyota Avanza vehicle in recognition of her performance.
• Although the vehicle was provided for work purposes—and its ownership remained with JUPP—the company unilaterally deducted amounts (P113,000.00 as car plan participation and P68,721.36 as one-year rental payment) from her unpaid commission without an express agreement authorizing such deductions.

Resignation and Claim for Payment

• On February 4, 2013, Asentista tendered her resignation, effective February 28, 2013, and returned the Toyota Avanza to the company.
• She subsequently computed her unpaid sales commission based on her earnings from 2010 to 2012, arriving at a total claim of P210,077.95 after accounting for cash advances and previously deposited commissions.

Proceedings Before Labor Arbiters and NLRC

• Asentista filed a complaint before the NLRC Regional Arbitration Branch No. 10 in Cagayan de Oro City for non-payment of her sales commission and for a refund of the deducted amounts related to the car plan.
• In a Decision dated November 28, 2013, the Labor Arbiter dismissed her complaint for lack of merit, emphasizing the absence of any express contractual provision entitling her to such payments.
• On appeal, the NLRC reversed the Labor Arbiter’s decision in a Resolution dated November 28, 2014, finding that the respondents lacked authority to forfeit her earned commission and improperly deducted car-related payments.
• The respondents then sought relief from the Court of Appeals, which, in its Decision dated August 31, 2016, reinstated the Labor Arbiter’s ruling, rejecting the evidentiary value of the electronic messages submitted by Asentista’s side.

Petition for Review and Contentions of the Parties

• Asentista filed a Petition for Review on Certiorari before the Supreme Court under Rule 45 challenging both the CA’s Decision and NLRC’s prior rulings.
• Asentista argued that she was entitled to the unpaid commission and that the deductions for the car plan were unauthorized since no agreement was reached on such terms.
• Respondents contended that the employment agreement did not expressly include a sales commission or a car participation plan, and the burden of proof to substantiate any monetary claims rested solely on her.
• The dispute hinged on whether discretionary practices and evidentiary admissions by respondents could create an implied entitlement to commission and whether the deductions were justified.

Issue:

Entitlement to Unpaid Sales Commission

• Is Asentista entitled to receive her unpaid sales commission even though the employment agreement did not expressly stipulate a commission as part of her remuneration?
• Can a discretionary commission, recognized in practice by the employer, be treated as part of the employee’s wages?

Validity of Car Plan Deductions

• Were the unilateral deductions for car plan participation and rental payments from Asentista’s commission legally permissible given the absence of an express agreement?
• Do such deductions amount to an unjust enrichment of the employer?

Evidentiary and Burden of Proof Considerations

• In cases of non-payment of monetary claims, does the burden of proof rest on the employee or the employer?
• Can Asentista’s submission of electronic messages and computations suffice to establish her claim against the respondents?

Appropriateness of the CA’s Ruling

• Did the Court of Appeals rightly reverse the NLRC’s findings by rejecting the evidence presented by Asentista?
• Is the reversal and the reinstatement of the NLRC decision consistent with established labor doctrines?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)