G.R. No. 87210 . July 16, 1990.
FILOMENA BARCENAS, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION (NLRC), REV. SIM DEE, MANUEL CHUA, et al., respondents.

FACTS

Petitioner Filomena Barcenas was hired in 1978 by Chua Se Su, the Head Monk and President of the Poh Toh Buddhist Association of the Philippines, Inc., as a secretary and interpreter. Her duties included assisting Chinese temple visitors, acting as a tourist guide and liaison, and paying utility bills. She received a salary, a monthly allowance, and free board and lodging. In May 1982, five months before giving birth to a child allegedly fathered by Su, she was sent home to Bicol. She did not return to work until after Su’s death in July 1983.
Upon Su’s death, new officers, respondents Rev. Sim Dee and Manuel Chua, assumed their positions. They discontinued her allowances and, in 1986, forcibly evicted her from the temple. She was offered P10,000.00 to sign an undertaking not to return, which she refused. She filed a labor case for illegal dismissal, backwages, separation pay, and damages. The Labor Arbiter ruled in her favor, but the NLRC reversed, holding no employer-employee relationship existed.

ISSUE

Whether an employer-employee relationship existed between Barcenas and the respondents, justifying her money claims.

RULING

The Supreme Court affirmed the NLRC’s decision, dismissing the petition. The legal logic proceeds in two stages. First, the Court found that Barcenas was initially a regular employee of the temple from 1978. Her tasks were integral to the temple’s religious and operational functions, not mere domestic service. The President’s power to hire under the association’s by-laws was upheld, and the lack of prior board approval did not negate the employment, as her long service constituted tacit ratification.
However, the Court ruled this employment status ended in May 1982 when she left for Bicol to give birth. The records showed she did not file for or was granted a leave of absence, nor did she return to work after childbirth. This constituted abandonment of her position. Her return in July 1983, after Su’s death, was not a resumption of employment but was motivated by a personal desire, as Su’s mistress, to protect her son’s alleged hereditary rights in the temple. The new management did not re-hire her; they explicitly rejected her services. Her subsequent presence and unsalaried work were performed under her own insistence, not under any contract of hire. Consequently, no employer-employee relationship was re-established with the new administrators. Furthermore, her money claims, filed only in 1986 for wages accruing from 1982, were barred by prescription under Article 292 of the Labor Code, which requires such claims to be filed within three years.