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CORAZON C. SIM vs. NLRC

The Supreme Court ruled that the Philippine labor relations system has extra-territorial jurisdiction over labor disputes involving overseas Filipino workers. Article 217 of the Labor Code and Section 10 of the Migrant Workers Act grant original and exclusive jurisdiction to Labor Arbiters over claims arising from employer-employee relationships. Section 62 of the Rules implementing the Migrant Workers Act also confirms the jurisdiction of Labor Arbiters over disputes involving Filipino overseas workers. Prior jurisprudence also established that Filipino workers enjoy the protection of Philippine labor laws regardless of whether employed locally or overseas.

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59 views1 page

CORAZON C. SIM vs. NLRC

The Supreme Court ruled that the Philippine labor relations system has extra-territorial jurisdiction over labor disputes involving overseas Filipino workers. Article 217 of the Labor Code and Section 10 of the Migrant Workers Act grant original and exclusive jurisdiction to Labor Arbiters over claims arising from employer-employee relationships. Section 62 of the Rules implementing the Migrant Workers Act also confirms the jurisdiction of Labor Arbiters over disputes involving Filipino overseas workers. Prior jurisprudence also established that Filipino workers enjoy the protection of Philippine labor laws regardless of whether employed locally or overseas.

Uploaded by

PAMELA PARCE
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No.

157376; October 2, 2007


CORAZON C. SIM vs. NLRC

FACTS: Corazon Sim filed a case for illegal dismissal with the Labor Arbiter, alleging that she
was initially employed by Equitable PCI-Bank 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.

Respondent denied any employer-employee relationship between them, and sought the
dismissal of the complaint.

The LA rendered its Decision dismissing the case stressing that the labor relations system in the
Philippines has no extra-territorial jurisdiction. The decision was affirmed by the NLRC.

ISSUE: Whether or not the labor relations system in the Philippines has extra-territorial
jurisdiction.

RULING: YES, labor relations system in the Philippines has extra-territorial jurisdiction.

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

Also, Section 62 of the Omnibus Rules and Regulations Implementing R.A. No. 8042 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.

In Philippine National Bank v. Cabansag, the Court pronounced:

x x x Whether employed locally or overseas, all Filipino workers enjoy the protective mantle of
Philippine labor and social legislation, contract stipulations to the contrary notwithstanding. This
pronouncement is in keeping with the basic public policy of the State to afford protection to
labor, promote full employment, ensure equal work opportunities regardless of sex, race or
creed, and regulate the relations between workers and employers. For the State assures the
basic rights of all workers to self-organization, collective bargaining, security of tenure, and just
and humane conditions of work [Article 3 of the Labor Code of the Philippines; See also Section
18, Article II and Section 3, Article XIII, 1987 Constitution]. This ruling is likewise rendered
imperative by Article 17 of the Civil Code which states that laws "which have for their object
public order, public policy and good customs shall not be rendered ineffective by laws or
judgments promulgated, or by determination or conventions agreed upon in a foreign country."

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