Case Summary (G.R. No. 116347)
Factual Background
Andres Pondoc worked for Eulalio Pondoc from October 1990 until December 1991, earning a daily wage of P20.00 but did not receive premium pay for work performed during holidays and rest days. Natividad Pondoc filed a complaint on May 14, 1992, seeking total claims for salary differentials, overtime, holiday pay, and other monetary benefits, which the Labor Arbiter later ruled in favor of, determining the existence of an employer-employee relationship.
Labor Arbiter's Decision
On June 17, 1993, Labor Arbiter Esteban Abecia ordered Eulalio Pondoc to pay Natividad Pondoc P44,118.00, covering the claims filed. Eulalio Pondoc filed a motion for a set-off against this award, which the Labor Arbiter denied, issuing a writ of execution instead.
NLRC Involvement
Eulalio Pondoc then obtained a restraining order from the NLRC and filed a petition for "Injunction and Damages," where he sought to offset a claimed debt he asserted against Natividad Pondoc. On February 28, 1994, the NLRC vacated the Labor Arbiter's order, allowing the set-off and determining Natividad Pondoc's alleged indebtedness.
Petitioner’s Argument
Natividad Pondoc challenged the NLRC's decision, asserting the Labor Arbiter had rendered a final and executory ruling. She claimed the NLRC lacked jurisdiction to entertain the independent petition for injunction and damages, and that the asserted claim for set-off had not been raised adequately prior to the final ruling.
Legal Findings
The Supreme Court ruled in favor of Natividad Pondoc, stating that the NLRC had overstepped its jurisdiction by entertaining the petition for injunction, which was essentially a ploy to evade the Labor Arbiter’s execution order. The Court highlighted that the NLRC had no jurisdiction over claims not under their original jurisdiction.
Jurisdictional Errors
The Court emphasized that the NLRC lacked both original and appellate jurisdiction over Eulalio Pondoc's claim for set-off, which constituted an independent claim that had not been prop
...continue readingCase Syllabus (G.R. No. 116347)
Case Overview
- This case addresses whether the National Labor Relations Commission (NLRC) can override a final judgment from a labor arbiter by reviewing a petition for injunction and damages alongside an appeal based on an alleged set-off claim by the employer.
- The petitioner, Natividad Pondoc, represents her deceased husband, Andres Pondoc, in a labor dispute against Emilio Pondoc, the employer.
Factual Antecedents
- Natividad Pondoc was the legitimate wife of Andres Pondoc, who was employed by Eulalio Pondoc at Melleonor General Merchandise from October 1990 to December 1991.
- Andres was paid P20.00 per day for working twelve hours daily, without receiving proper compensation for premium pay during holidays or rest days.
- On May 14, 1992, Natividad Pondoc filed a complaint for various claims (salary differential, overtime pay, holiday pay, etc.) before the NLRC, which was later docketed as Sub-RAB Case No. 09-05-10102-92.
- Eulalio Pondoc challenged the existence of an employer-employee relationship and claimed the business was fictitious.
Labor Arbiter's Decision
- On June 17, 1993, Labor Arbiter Esteban Abecia ruled in favor of Natividad Pondoc, confirming the employer-employee relationship and ordering Eulalio to pay a total of P44,118.00 in claims.
- Eulalio Pondoc, on the last day for appeal,