The principles
§ Jurisdiction of regular courts
§ Payment of employment bond
FIRST DIVISION
G.R. No. 222212, January 22, 2020
COMSCENTRE PIDLS., INC.,
v. CAMILLE B. ROCIO
LAZARO-JAVIER, J.:
In April 2011, petitioners hired respondent Rocio as a Network Engineer. On August 5, 2011,
Rocio informed petitioner of her intention to resign effective September 9, 2011. The Human
Resource Manager informed Rocio that she had to pay an employment bond of P80,000.00 for
resigning within 24 months from the time she got employed as provided in her employment
contract.
Respondent was preventively suspended without pay due to her alleged actions causing
chaos, disarray/turmoil amongst co-employees and the whole working environment and thus
jeopardizing and putting the company operations at high risk and hampering over-all productivity.
Consequently, Rocio sued petitioners for unfair labor practice, illegal suspension, illegal
deduction, among others.
The Labor Arbiter ruled in favor of respondent. The National Labor Relations Commission
affirmed the ruling of the Labor Arbiter with modification. The NLRC ordered the deduction of the
P80,000.00 "employment bond" claimed by petitioners from respondent's total monetary award.
The Court of Appeals nullified the NLRC's directive to deduct the P80,000.00. It ruled that
petitioner's claim for payment of "employment bond" is within the exclusive jurisdiction of regular
courts.
Hence, this petition.
§ Jurisdiction of regular courts
Q. Does the claim for payment of employment bond fall within the jurisdiction of
regular courts?
Article 224 of the Labor Code clothes the labor tribunals with original and exclusive jurisdiction
over claims for damages arising from employer¬ employee relationship, viz:
Art. 224. Jurisdiction of Labor Arbiters and the Commission. - (a) Except as otherwise
provided under this Code, the Labor Arbiters shall have original and exclusive jurisdiction to hear
and decide, within thirty (30) calendar days after the submission of the case by the parties for
decision without extension, even in the absence of stenographic notes, the following cases involving
all workers, whether agricultural or non-agricultural:
1. Unfair labor practices;
2. Termination disputes;
3. If accompanied with a claim for reinstatement, those cases that workers may file involving
wages, rates of pay, hours of work and other terms and conditions of employment;
4. Claims for actual, moral, exemplary and other forms of damages arising from the employer-
employee relations;
xxx xxx xxx.
In Bañez v. Valdevilla, the Court elucidated that the jurisdiction of labor tribunals is
comprehensive enough to include claims for all forms of damages "arising from the employer-
employee relations." Thus, the Court decreed therein that labor tribunals have jurisdiction to award
not only the reliefs provided by labor laws, but also damages governed by the Civil Code.
Further, in Supra Multi-Services, Inc. v. Labitigan, while we recognized that Article 224 of the
Labor Code had been invariably applied to claims for damages filed by an employee against the
employer, we held that the law should also apply with equal force to an employer's claim for
damages against its dismissed employee, provided that the claim arises from or is necessarily
connected with the fact of termination and should be entered as a counterclaim in the illegal
dismissal case. Thus, the "reasonable causal connection with the employer-employee relationship"
is a requirement not only in employees' money claims against the employer but is, likewise, a
condition when the claimant is the employer.
§ Payment of employment bond
Q. When is an employee liable for payment of employment bond?
Here, the controversy was rooted in respondent's resignation from the company within twenty-
four (24) months from the time she got employed in violation of the "Minimum Employment Length"
clause of her employment contract. When respondent informed petitioners of her intention to resign
merely five (5) months after she got hired, they reminded respondent of her obligation to pay the
"employment bond" of Eighty Thousand Pesos (P80,000.00) as indemnity for the expenses the
company incurred in her training as Network Engineer. This prompted respondent to seek
clarification by e-mail from Comscentre's Australian Human Resource Manager Lianne Glass. But
as it was, petitioners found respondent's act of directly addressing her query to Manager Glass to be
in violation of company directives. For this supposed infraction, she was suspended until September
9, 2011, the date her resignation was to take effect. Consequently, respondent sued petitioners for
illegal suspension and money claims before the labor arbiter. Petitioners, in turn, pursued their claim
for payment of "employment bond" in the same proceedings.
It is clear that petitioners' claim for payment is inseparably intertwined with the parties'
employer-employee relationship. For it was respondent's act of prematurely severing her
employment with the company which gave rise to the latter's cause of action for payment of
"employment bond." As aptly found by the NLRC, petitioners' claim was "an offshoot of the
resignation of respondent and the complications arising therefrom and which eventually led to the
filing of the case before the Labor Arbiter." Verily, petitioners' claim falls within the original and
exclusive jurisdiction of the labor tribunals.
On this score, we further sustain the NLRC ' s finding that respondent is liable for payment of
"employment bond" pursuant to her undertaking in the employment contract. She herself has not
disputed this liability arising as it did from her breach of the minimum employment period clause.29
Notably, she committed to abide thereby in exchange for the expenses incurred by the company for
her training as Network Engineer. As correctly ruled by the NLRC:
There is basis to [petitioners'] claim that [respondent] is "liable to pay the employment bond, in
the sum of Eighty Thousand Pesos (P80,000.00)". Respondent did not dispute the Minimum
Employment Length provision in her contract which reads:
xxx xxx xxx
Except for claiming that the matter of refund was raised for the first time on appeal,
respondent did not dispute the existence and validity of such provision in her employment contract,
a contract which she voluntarily entered into, fully understanding its meaning and repercussions. It
should be stated that contrary to respondent's argument, this claim was already ventilated in the
proceedings before the Labor Arbiter, as stated in their Position Paper.
Surely, while petitioners are liable to respondent for her illegal suspension and unpaid money
claims, respondent, too, is liable to petitioners for payment of the "employment bond." As such, the
NLRC correctly ordered the offsetting of their respective money claims against each other. To rule
otherwise would be "to sanction split jurisdiction, which is prejudicial to the orderly administration of
justice."
