3/31/2021
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4. Claims for actual, moral, exemplary and other forms of damages
arising from the employer-employee relations;
xxx xxx xxx. (emphasis supplied)
In Bañez v. Valdevilla,[23] 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.[24]
Further, in Supra Multi-Services, Inc. v. Labitigan,[25] 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.[26]
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"[27] 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.[28] 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
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