Facts:

• Westmont Pharmaceuticals, Inc. and United Laboratories, Inc. are the petitioners; Ricardo C. Samaniego is the respondent.
• Samaniego filed a complaint for illegal dismissal and damages on May 5, 1998, at the Labor Arbiter's office in Tuguegarao City.
• He was initially hired as a Professional Service Representative, later promoted to Senior Business Development Associate, and eventually assigned as Acting District Manager in Isabela.
• In August 1995, he was transferred to Metro Manila pending an investigation of his subordinates, which resulted in a salary reduction and "floating status" with menial tasks.
• On June 26, 1998, Westmont and Unilab filed a motion to dismiss the complaint, citing improper venue and lack of cause of action; the Labor Arbiter denied this motion.
• The Labor Arbiter determined that Samaniego was constructively dismissed and ordered his reinstatement, backwages, and damages.
• Westmont and Unilab appealed to the NLRC, which initially dismissed the appeal but later nullified the Labor Arbiter’s decision due to due process violations.
• The Court of Appeals reinstated the Labor Arbiter’s decision but modified the damages awarded.

Issue:

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Ruling:

• The Court of Appeals did not err in denying the motion to dismiss based on improper venue, affirming Tuguegarao City as the proper venue.
• The Court confirmed that Samaniego was constructively dismissed.
• The court ruled that Westmont and Unilab were not denied due process.
• Samaniego was granted sepa...(Unlock)

Ratio:

• The Supreme Court held that a petition to change or transfer venue was not the appropriate remedy against the Labor Arbiter's order denying the motion to dismiss, as such orders are interlocutory and not appealable.
• Labor cases should be filed in the Regional Arbitration Branch where the complainant's wor...continue reading