G.R. No. 168550 - Moreno vs. Commission on Elections

Petitioner Purificacion Tabang was a founding member, member of the Board of Trustees, and corporate secretary of respondent Pamana Golden Care Medical Center Foundation, Inc. (a non-stock corporation providing medical and surgical services).
On October 30, 1990, the Board of Trustees appointed petitioner as Medical Director and Hospital Administrator of the medical center through a memorandum. The memorandum did not specify remuneration.
Petitioner claimed that she received a monthly retainer fee of ₱5,000 from the respondent but alleged that payment stopped in November 1991.
Her duties included running the affairs of the medical center and performing administrative acts relative to its daily operations.

On May 1, 1993, petitioner was allegedly informed by Dr. Ernesto Naval that the Board of Trustees, in a special meeting held on April 30, 1993, passed a resolution relieving her from her positions. Dr. Naval and Dr. Donasco were appointed acting Medical Director and acting Hospital Administrator, respectively.
Petitioner received a copy of this board resolution.
On June 6, 1993, petitioner filed a complaint before the labor arbiter for illegal dismissal and non-payment of wages, allowances, and 13th month pay.

Respondent moved to dismiss for lack of jurisdiction, asserting that petitioner's position was interlinked with her role as Board Trustee, thus making her dismissal an intra-corporate controversy under the exclusive jurisdiction of the Securities and Exchange Commission (SEC).
Petitioner opposed, claiming that her position as Medical Director and Hospital Administrator was distinct from her trustee role and that the complaint was filed in her capacity as employee.

On April 26, 1994, the labor arbiter dismissed the complaint for lack of jurisdiction, ruling that the SEC had jurisdiction under Section 5 of Presidential Decree No. 902-A.
Petitioner’s motion for reconsideration was treated as an appeal and forwarded to the National Labor Relations Commission (NLRC).
NLRC affirmed the dismissal, stating that petitioner’s position was akin to an executive officer and thus her removal was an intra-corporate controversy under the SEC’s jurisdiction.

Aggrieved, petitioner filed the present petition for certiorari seeking to annul the NLRC resolution.
The Supreme Court found the petition without merit and affirmed the NLRC decision.

Whether the Labor Arbiter and the NLRC had jurisdiction to entertain petitioner’s complaint for illegal dismissal and non-payment of wages.
Whether petitioner’s position as Medical Director and Hospital Administrator is considered an employment relationship subject to labor law jurisdiction or an intra-corporate controversy under the jurisdiction of the SEC.
Whether the payments received by petitioner constituted compensation as an employee or professional fees as an independent retained physician.