Title
Barcenas vs. National Labor Relations Commission
Case
G.R. No. 87210
Decision Date
Jul 16, 1990
Filomena Barcenas, employed by a Buddhist temple, claimed unpaid wages and benefits after her relationship with the Head Monk ended. The Supreme Court ruled no employer-employee relationship existed post-1982, and her claims had prescribed.
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Case Digest (G.R. No. 87210)

Facts:

  1. Employment Details:

    • In 1978, Filomena Barcenas was hired by Chua Se Su (Su), the Head Monk of the Manila and Baguio Buddhist Temples and President of the Poh Toh Buddhist Association of the Philippines, Inc.
    • She was employed as a secretary and interpreter, tasked with assisting Chinese visitors, acting as a tourist guide, attending to the Head Monk's callers, preparing food for temple visitors, running errands (e.g., paying utility bills), and liaising with government offices.
    • She received a monthly salary, allowances, and an additional P500.00, along with free board and lodging in the temple.
  2. Personal Relationship:

    • In 1981, Barcenas and Su entered into an amorous relationship.
    • In May 1982, five months before giving birth to Su’s alleged son, Barcenas was sent home to Bicol.
    • After Su’s death in July 1983, Barcenas returned to the temple, claiming it was based on Su’s deathbed instructions to care for her son and nephew and ensure they became monks.
  3. Discontinuation of Benefits and Eviction:

    • In 1985, Manuel Chua became President of the Poh Toh Buddhist Association, and Rev. Sim Dee became the Head Monk.
    • They discontinued Barcenas’ monthly allowance and additional P500.00, effective 1983.
    • Barcenas and her son were forcibly evicted from the temple by police officers, and she was pressured to sign a written undertaking not to return in exchange for P10,000.00, which she refused.
  4. Labor Arbiter’s Decision:

    • On February 10, 1988, the Labor Arbiter ruled in favor of Barcenas, awarding her backwages, separation pay, unpaid wages, and moral damages.
  5. NLRC’s Reversal:

    • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, ruling that no employer-employee relationship existed between Barcenas and the respondents.

Issue:

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Ruling:

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Ratio:

  1. Employer-Employee Relationship:

    • The existence of an employer-employee relationship is determined by the "four-fold test": (a) selection and engagement of the employee, (b) payment of wages, (c) power of dismissal, and (d) control over the employee’s work.
    • While Barcenas initially met these criteria, her abandonment of her position in May 1982 and her subsequent return under personal circumstances severed the employment relationship.
  2. Prescription of Claims:

    • Money claims arising from employer-employee relationships must be filed within three years from the accrual of the cause of action, as provided under Article 292 of the Labor Code.
  3. Abandonment of Employment:

    • Barcenas’ failure to return to work after her leave and her subsequent actions demonstrated abandonment of her position, which precluded any reinstatement of the employer-employee relationship.


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