Case Name: Milan v.

NLRC, February 4, 2015 made it incumbent upon petitioners to turn over the property to Solid Mills
G.R. Number: G.R. No. 20296 - Petitioners point out that the NLRC and the CA have no jurisdiction to declare
Topic: Labor Arbiter Author: Lauredo, Caleb L. that petitioners’ act of withholding possession of respondent Solid Mills’
property is illegal.
- Doctrine: Article 217 provides that the Labor Arbiter, in his or her original
jurisdiction, and the NLRC, in its appellate jurisdiction, may determine issues Issue: -WON the NLRC has jurisdiction over the subject matter - YES
involving claims arising from employer-employee relations. Claims arising
Held/Ratio:
from an employer-employee relationship are not limited to claims by an
- The NLRC may preliminarily determine issues related to rights
employee. Employers may also have claims against the employee, which arise
arising from an employer-employee relationship. NLRC has jurisdiction to
from the same relationship.
determine, preliminarily, the parties’ rights over a property, when it is necessary
Facts: to determine an issue related to rights or claims arising from an employer-
- As Solid Mills’ employees, petitioners and their families were allowed to occupy employee relationship.
SMI Village, a property owned by Solid Mills. According to Solid Mills, this was - Article 217 provides that the Labor Arbiter, in his or her original jurisdiction, and
“[o]ut of liberality and for the convenience of its employees . . . [and] on the the NLRC, in its appellate jurisdiction, may determine issues involving claims
condition that the employees . . . would vacate the premises anytime the arising from employer-employee relations.
Company deems fit - Claims arising from an employer-employee relationship are not limited to claims
- Afterwards, petitioners were informed that Solid Mills would cease its by an employee. Employers may also have claims against the employee, which
operations due to serious business losses. NAFLU recognized Solid Mills’ closure arise from the same relationship.
due to serious business losses in the memorandum of agreement. The MOA - In Bañez v. Valdevilla, the court ruled that Art. 217 also applies to employers’
provided for Solid Mills’ grant of separation pay less accountabilities, accrued claim for damages, which arises from or is connected with the labor issue.
sick leave benefits, vacation leave benefits, and 13th month pay to the - In this case, respondent that its properties are in petitioners’ possession by
employees. virtue of their status as its employees. Respondent allowed petitioners to use
- Later, Solid Mills, through Alfredo Jingco, sent to petitioners individual notices its property as an act of liberality. Put in other words, it would not have allowed
to vacate SMI Village. petitioners to use its property had they not been its employees. The return of
- Petitioners were no longer allowed to report for work. They were required to its properties in petitioners’ possession by virtue of their status as employees is
sign a MOA with release and quitclaim before their vacation and sick leave an issue that must be resolved to determine whether benefits can be released
benefits, 13th month pay, and separation pay would be released. Employees immediately. The issue raised by the employer is, therefore, connected to
who signed the MOA were considered to have agreed to vacate SMI Village, and petitioners’ claim for benefits and is sufficiently intertwined with the parties’
to the demolition of the constructed houses inside as condition for the release employer-employee relationship. Thus, it is properly within the labor tribunals’
of their termination benefits and separation pay. Petitioners refused to sign the jurisdiction
documents and demanded to be paid their benefits and separation pay. - Clearly, in this case, it is for the workers to return their housing in exchange for
- Petitioners filed complaints before the LA non-payment of separation pay, the release of their benefits. This is what they agreed upon. It is what is fair in
accrued leaves, and 13th month pay. They argued that their accrued benefits the premises.
and separation pay should not be withheld because their payment is based on
company policy and practice.
- LA ruled in favor of petitioners stating that petitioners’ right to the payment of
their benefits and separation pay was vested by law and contract. The first MOA
stated no condition to the effect that petitioners must vacate Solid Mills’
property before their benefits could be given to them. Petitioners’ possession
should not be construed as petitioners’ “accountabilities” that must be cleared
first before the release of benefits.
- Their possession “is not by virtue of any employer-employee relationship.” It is a
civil issue, which is outside the jurisdiction of the LA.
- NLRC affirmed the LA stating that petitioners were already paid.
- It also ruled that because of petitioners’ failure to vacate Solid Mills’ property,
Solid Mills was justified in withholding their benefits and separation pay. Solid
Mills granted the petitioners the privilege to occupy its property on account of
petitioners’ employment. It had the prerogative to terminate such privilege. The
termination of Solid Mills and petitioners’ employer-employee relationship