GR 161757; (January, 2006) (Digest)
G.R. No. 161757; January 25, 2006
SUNACE INTERNATIONAL MANAGEMENT SERVICES, INC., Petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, Second Division; HON. ERNESTO S. DINOPOL, in his capacity as Labor Arbiter, NLRC; NCR, Arbitration Branch, Quezon City and DIVINA A. MONTEHERMOZO, Respondents.
FACTS
Petitioner Sunace International Management Services deployed respondent Divina A. Montehermozo to Taiwan as a domestic helper under a 12-month contract effective February 1, 1997. After the contract expired on February 1, 1998, Montehermozo continued working for her Taiwanese employer for two more years without returning to the Philippines. Upon her return on February 4, 2000, she filed a complaint against Sunace before the NLRC, claiming illegal deductions from her salary for income tax and savings during the extended two-year period.
Sunace initially argued in its position paper that the deductions were lawful and complied with Taiwanese law. It later filed a supplemental answer, contending that the two-year contract extension was executed without its knowledge and consent, and that Montehermozo had executed a Waiver/Quitclaim and an Affidavit of Desistance. The Labor Arbiter ruled in favor of Montehermozo, holding Sunace solidarily liable. This decision was affirmed by the NLRC and the Court of Appeals, which presumed Sunace’s consent to the extension due to its continued communication with the Taiwanese broker and its failure to formally object.
ISSUE
Whether petitioner Sunace International Management Services, Inc. can be held solidarily liable for the monetary claims of respondent Montehermozo arising from her two-year extended employment contract in Taiwan.
RULING
No. The Supreme Court reversed the rulings of the lower tribunals and dismissed the complaint against Sunace. The Court held that the principle of relativity of contracts under Article 1311 of the Civil Code governs. The original 12-month employment contract had already been fully performed and terminated. The subsequent two-year extension was a new contract negotiated directly between Montehermozo and her foreign employer in Taiwan, to which Sunace was not a party. There was no evidence that Sunace had knowledge of or consented to this new contract.
The Court further ruled that the agency relationship between Sunace and its foreign principal was impliedly revoked under Article 1924 of the Civil Code when the principal directly negotiated with and re-hired Montehermozo after the termination of the original contract. Consequently, Sunace ceased to be the agent for that new employment arrangement. Being non-privy to the extended contract, Sunace cannot be held solidarily liable for any claims arising from it. The Court found it unnecessary to rule on the validity of the Waiver and Affidavit of Desistance due to this dispositive legal conclusion.