G.R. No. 117650 March 7, 1996
Sulpicio Lines, Inc., petitioner, vs. National Labor Relations Commission and Jaime Cagatan, respondents.

FACTS

Petitioner Sulpicio Lines, Inc. dismissed private respondent Jaime Cagatan, a messman aboard the MV Cotabato Princess, for alleged prolonged absence without leave. Cagatan subsequently filed a complaint for illegal dismissal with the National Labor Relations Commission (NLRC) National Capital Region Arbitration Branch in Manila. Sulpicio Lines moved to dismiss the complaint on grounds of improper venue, contending that under the NLRC Rules, the case should have been filed with Regional Branch No. VII in Cebu City, where its principal office is located. The Labor Arbiter denied the motion, ruling that since Cagatan was a ship steward whose vessel plied a route including Manila, Manila could be considered part of his territorial workplace.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in sustaining the Labor Arbiter’s denial of the Motion to Dismiss based on improper venue.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The Court explained that rules on venue are primarily designed for the convenience of the parties and the ends of justice, not as a substantive jurisdictional hurdle. The constitutional mandate to afford full protection to labor is a paramount consideration. The NLRC Rules on venue, particularly Section 1, Rule IV, are permissive, using the word “may,” and do not impose an absolute, restrictive requirement. The Court cited precedent establishing that contractual stipulations on venue, especially in contracts of adhesion, can be set aside if they are grossly inconvenient to one party and would effectively negate a claim. Applying these principles, the Court noted that while Sulpicio Lines’ principal office is in Cebu, it maintains a major booking and shipping office in Manila. Requiring Cagatan, a Manila resident, to litigate in Cebu would be oppressive and financially burdensome, potentially discouraging him from pursuing his claim. Conversely, the petitioner, with offices in multiple ports, would not be unduly inconvenienced by proceedings in Manila. The definition of “workplace” for venue purposes includes the locality where the employee is regularly assigned. As Cagatan was assigned to a vessel whose regular route included Manila, the Labor Arbiter correctly considered it part of his territorial workplace. Thus, the NLRC’s decision to allow the case to proceed in Manila was a valid exercise of discretion aimed at serving substantial justice.