GR 116347; (October, 1996) (Digest)
G.R. No. 116347 October 3, 1996
NATIVIDAD PONDOC, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (Fifth Division, Cagayan de Oro City) and EMILIO PONDOC, respondents.
FACTS
Petitioner Natividad Pondoc, on behalf of her husband Andres, filed a labor complaint for various monetary claims against private respondent Emilio Pondoc. Labor Arbiter Esteban Abecia ruled in her favor, ordering Emilio to pay P44,118.00. The decision became final and executory as the respondent failed to appeal. On the last day to appeal, however, Emilio filed a manifestation before the Labor Arbiter praying that his liability be set off against an alleged indebtedness of Andres to him. The Labor Arbiter denied this claim for compensation and issued a writ of execution.
To obstruct the execution, Emilio filed a separate “Petition for Injunction and Damages” before the NLRC’s Fifth Division, docketed as a new case. The NLRC then entertained this petition, received evidence on the alleged debt, and subsequently issued a decision allowing the set-off of P41,051.35 from the labor award, reducing the payable amount to P3,066.65.
ISSUE
Whether the NLRC acted without or in excess of jurisdiction or with grave abuse of discretion in entertaining a separate petition to adjudicate a claim for set-off against a final and executory labor judgment.
RULING
The Supreme Court ruled for the petitioner, annulling the NLRC’s decision. The NLRC proceedings were fatally flawed. First, the separate petition for injunction was a mere scheme to defeat the final judgment of the Labor Arbiter and should not have been entertained. Second, the NLRC lacked jurisdiction over the claim for indebtedness. Under the Labor Code, Labor Arbiters have original and exclusive jurisdiction over claims arising from employer-employee relations, while the NLRC’s jurisdiction is appellate. The alleged debt, being a purely civil obligation not arising from the employment relationship, fell outside the jurisdiction of both the Labor Arbiter and the NLRC. Finally, even assuming arguendo that the claim was within the Labor Arbiter’s jurisdiction, it was deemed waived for not having been pleaded as an affirmative defense or a compulsory counterclaim in the original labor case prior to judgment. Consequently, the NLRC acted without jurisdiction and with grave abuse of discretion. The final judgment of the Labor Arbiter was ordered enforced in full.