Sim vs NLRC (Labor Law)

Sim vs NLRC

GR No. 157376, 

October 2, 2007

 Facts:

Corazon Sim (petitioner) filed a case for illegal dismissal with the Labor Arbiter, alleging that she was initially employed by Equitable PCI-Bank (respondent) in 1990 as Italian Remittance Marketing Consultant to the Frankfurt Representative Office. Eventually, she was promoted to Manager position, until September 1999, when she received a letter from Remegio David, the Senior Officer, European Head of PCI Bank, and Managing Director of PCIB- Europe, informing her that she was being dismissed due to loss of trust and confidence based on alleged mismanagement and misappropriation of funds. The Labor Arbiter dismissed the case for want of jurisdiction and/or lack of merit stressing that the labor relations system in the Philippines has no extra-territorial jurisdiction. The NLRC affirmed the Labor Arbiter's decision and dismissed petitioner's appeal for lack of merit.

 Issue:

WON the Labor Arbiter has extra-territorial jurisdiction.

 Ruling:

Article 217 of the Labor Code provides for the jurisdiction of the Labor Arbiter and the National Labor Relations Commission x x x Moreover, Section 10 of Republic Act (R.A.) No. 8042, or the Migrant Workers and Overseas Filipinos Act of 1995,18 provides:

SECTION 10. Money Claims.  Notwithstanding any provision of law to the contrary, the Labor Arbiters of the NLRC shall have the original and exclusive jurisdiction to hear and decide, within 90 calendar days after the filing of the complaint, the claims arising out of an employer-employee relationship or by virtue of any law or contract involving Filipino workers for overseas deployment including claims for actual, moral, exemplary and other forms of damages. Also, Section 62 of the Omnibus Rules and Regulations Implementing R.A. No. 804219 provides that the Labor Arbiters of the NLRC shall have the original and exclusive jurisdiction to hear and decide all claims arising out of employer-employee relationship or by virtue of any law or contract involving Filipino workers for overseas deployment including claims for actual, moral, exemplary and other forms of damages, subject to the rules and procedures of the NLRC. 

Under these provisions, it is clear that labor arbiters have original and exclusive jurisdiction over claims arising from employer-employee relations, including termination disputes involving all workers, among whom are overseas Filipino workers.