G.R. No. 120223 - Alba vs. Deputy Ombudsman

Petitioner Sulpicio Lines, Inc. is the owner of MV Cotabato Princess.
On January 15, 1992, the petitioner dismissed private respondent Jaime Cagatan, a messman on the said vessel, for alleged prolonged absence without leave amounting to six (6) months.

Following the dismissal, Jaime Cagatan filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC) through its National Capital Region (NCR) Arbitration Branch, with docket number NLRC-NCR Case No. 00-06-3163-92.
The complaint prompted litigation concerning the proper venue for the filing of such cases under the NLRC rules.

On June 25, 1992, the petitioner filed a Motion to Dismiss the complaint on the ground of improper venue, contending that the case should be filed with the NLRC’s Regional Branch No. VII in Cebu because its main office is located in Cebu City.
The petitioner argued that a ship or vessel as a workplace is merely an extension of its homeport or principal place of business, urging that the territorial jurisdiction of the case should therefore be where the homeport is located (i.e., Cebu City).

Labor Arbiter Arthur L. Amansec of the NLRC-NCR, in an Order dated August 21, 1992, denied the petitioner's Motion to Dismiss. He held that because the complainant, being a ship steward traveling on the vessel’s route which includes Manila, could establish Manila as part of his territorial workplace.
The petitioner appealed the Labor Arbiter’s ruling, but on February 28, 1994, the NLRC sustained the earlier ruling, finding that under the NLRC’s permissive venue rules a change of venue could be warranted, and emphasized that the plaintiff instituted the action in Manila where he resided.
The petitioner’s request for reconsideration was denied by the public respondent NLRC on July 22, 1994.

Petitioner Sulpicio Lines, Inc. sought relief through a Special Civil Action for Certiorari under Rule 65 of the Rules of Court, alleging grave abuse of discretion on the part of the NLRC in sustaining the Labor Arbiter’s ruling.
The core contention was that the vessel-as-workplace is under the territorial jurisdiction of the Regional Arbitration Branch where the petitioner’s principal office is located (Cebu City), not where the complaint was filed (Manila).

The Supreme Court reviewed the case, referencing earlier decisions (e.g., Manila Railroad Company vs. Attorney General, 20 Phil. 523, 1911) to underline that the determination of venue relates to the convenience of the parties and the ends of justice.
The Court reiterated that any agreement on venue favoring convenience for the employer would not override the constitutional protection accorded to labor.
The petition's assertion was ultimately rejected as the NLRC properly allowed the filing in Manila based on the complainant’s regular assignment and the permissive language of the NLRC Rules regarding venue.

Whether the NLRC committed grave abuse of discretion in denying the petitioner’s Motion to Dismiss for improper venue.

Did the location of the workplace, as testified by the complainant’s regular assignment on the vessel, justify the filing of the case in the NCR rather than in the venue suggested by the petitioner?
Is the petitioner’s argument that a vessel is an extension of its homeport sufficient to shift the venue to the NLRC Regional Arbitration Branch in Cebu?

Whether the provisions of the NLRC Rules of Procedure on Venue adequately support the petitioner’s claim regarding the territorial jurisdiction of the ship (vessel).

How does the interpretation of “workplace” under Section 1, Rule IV of the NLRC Rules affect the determination of the proper venue?
Does the statutory and jurisprudential framework on venue, which prioritizes the convenience of the plaintiff, override the petitioner’s argument?