G.R. No. 161757 - Sunace International Management Services, Inc. vs. National Labor Relations Commission

Petitioner Sunace International Management Services, Inc. (“Sunace”), a Philippine corporation, deployed Divina A. Montehermozo (“Divina”) as a domestic helper to Taiwan under a 12-month contract effective February 1, 1997, through Taiwanese broker Edmund Wang of Jet Crown International Co., Ltd.
After the original contract expired on February 1, 1998, Divina continued working for her foreign employer, Hang Rui Xiong, purportedly under a two-year extension, and returned to the Philippines on February 4, 2000.

On February 14, 2000, Divina filed before the NLRC a complaint against Sunace, its manager Adelaide Perez, the Taiwanese broker, and the foreign employer, alleging she was unlawfully detained for three months in Taiwan and was underpaid income taxes and savings deductions for 1998 and 1999 amounting to NT45,800.00.
Sunace answered, denying liability for the extended contract and claiming Divina already recovered her savings and that tax deductions were mandated by Taiwanese law. It later asserted Divina had executed a waiver, quitclaim, and affidavit of desistance.

The Labor Arbiter found Sunace impliedly consented to the two-year extension by failing to protest to the POEA, thus presuming knowledge and consent, and struck down the waiver and desistance documents for lack of compliance with compulsory approval formalities.
Sunace was ordered to pay Divina NT91,950.00 (peso equivalent) plus 10% attorney’s fees. The NLRC, Second Division, affirmed on April 30, 2002.

The Court of Appeals denied Sunace’s petition for certiorari, holding that continuous communication with the broker imputed knowledge of the contract extension and binding Sunace as agent of the foreign principal. Motion for reconsideration was denied.
Sunace elevated the case to the Supreme Court via petition for review on certiorari.

Whether Sunace impliedly consented to and is liable for the two-year extension of Divina’s employment contract.
Whether the waiver, quitclaim, and affidavit of desistance executed by Divina are valid and bar her monetary claims.
Whether knowledge of the broker’s communications is imputed to Sunace as agent of the foreign principal, binding it to the extended contract.
Whether the power of taxation exercised by Taiwan and deductions made thereunder fall outside the jurisdiction of Philippine labor tribunals.