Pondoc v. NLRC

G.R. No. 116347 (October 3, 1996)

Supreme Court upheld Natividad Pondoc's award, annulling NLRC's jurisdiction on unraised claims.

Facts:

Petitioner Natividad Pondoc was the legitimate wife of Andres Pondoc, who was employed as a laborer by private respondent Eulalio Pondoc, owner of Melleonor General Merchandise and Hardware Supply, from October 1990 until December 1991. During his employment, Andres was paid a daily wage of P20.00 and was required to work twelve hours a day, seven days a week, without receiving the legally mandated premium pay for holidays and rest days.

On May 14, 1992, Natividad Pondoc filed a complaint on behalf of her husband for various money claims, including salary differentials, overtime pay, holiday pay, and 13th month pay, before the Sub-Regional Arbitration Branch of the National Labor Relations Commission (NLRC). The private respondent contested the existence of an employer-employee relationship and claimed that the business was fictitious.

On June 17, 1993, Labor Arbiter Esteban Abecia ruled in favor of Natividad, confirming the employer-employee relationship and ordering Eulalio to pay a total of P44,118.00 to Natividad. On the last day to appeal, Eulalio Pondoc filed a manifestation seeking to set off his alleged indebtedness to Andres against the monetary award. The Labor Arbiter denied this request and issued a writ of execution.

Before the execution could be carried out, Eulalio obtained a restraining order from the NLRC and filed a separate petition for "Injunction and Damages," which was docketed as NLRC Case No. ICM-000065. On February 28, 1994, the NLRC ruled in favor of Eulalio, allowing the set-off of the alleged indebtedness against the award, and ordered Natividad to be paid P3,066.65.

Natividad's motion for reconsideration was denied, prompting her to file a special civil action for certiorari under Rule 65, arguing that the NLRC acted without jurisdiction and in excess of its authority by entertaining the set-off claim and issuing a decision on it.

Legal Issues:

  1. Whether the NLRC could validly entertain a petition for injunction and damages that effectively sought to defeat a final judgment of the Labor Arbiter.
  2. Whether the NLRC had jurisdiction to adjudicate the alleged indebtedness of the laborer and authorize a set-off against the Labor Arbiter's final award.

Arguments:

  • Petitioner (Natividad Pondoc):

    • Argued that the NLRC acted without jurisdiction and with grave abuse of discretion by entertaining Eulalio's petition for injunction and damages, which was a scheme to obstruct the enforcement of the Labor Arbiter's final judgment.
    • Asserted that the alleged indebtedness was not related to the employer-employee relationship and thus fell outside the jurisdiction of the Labor Arbiter and the NLRC.
    • Contended that the claim for set-off was waived as it was not raised before the Labor Arbiter prior to the decision.
  • Respondents (NLRC and Eulalio Pondoc):

    • Argued for the dismissal of the petition, maintaining that the NLRC had the authority to entertain the petition for injunction and damages.
    • Claimed that the alleged indebtedness should be considered in the context of the labor dispute and could be set off against the monetary award.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of Natividad Pondoc, annulling the NLRC's decision and resolution. The Court held that the NLRC acted without jurisdiction in entertaining the independent petition for injunction and damages, as it was an attempt to circumvent the final judgment of the Labor Arbiter.

The Court emphasized that the NLRC does not have the authority to issue writs of injunction in labor disputes unless it is an ancillary remedy related to a case pending before it. The Court also noted that the appeal by Eulalio was not from the decision of the Labor Arbiter but from the order denying the set-off, which implicitly acknowledged the finality of the Labor Arbiter's judgment.

Furthermore, the Court found that the alleged indebtedness was not proven to arise from the employer-employee relationship, thus falling outside the jurisdiction of both the Labor Arbiter and the NLRC. The Court concluded that the claim for set-off was waived as it was not presented as an affirmative defense or counterclaim before the Labor Arbiter.

Significant Legal Principles Established:

  1. The NLRC does not have the authority to entertain independent petitions for injunction and damages that seek to obstruct the enforcement of a final judgment from a Labor Arbiter.
  2. Claims for set-off must be raised as affirmative defenses or counterclaims before the Labor Arbiter; failure to do so results in waiver.
  3. The jurisdiction of Labor Arbiters and the NLRC is limited to matters arising from the employer-employee relationship, and claims not related to this relationship fall outside their jurisdiction.