G.R. No. L-63185 February 27, 1987
EGYPTAIR and SAYED EZZAT, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and JOHN JOSEPH, respondents.

FACTS

John Joseph was employed by United Arab Airlines (later Egyptair) in 1962, eventually becoming its Sales Manager in the Philippines. His compensation included a salary and a commission based on sales. On January 22, 1974, he was appointed Marketing Adviser to the local manager, Sayed Ezzat. On May 6, 1974, Ezzat sent Joseph a letter stating that due to his continued unexcused absences from January 22 to May 6, 1974, he was considered resigned effective that date. Joseph filed a complaint for illegal dismissal and monetary claims just two days after receiving the letter.
The Labor Arbiter ruled in favor of Joseph, finding he was illegally dismissed and awarding backwages, unpaid salary, leave commutation, and unpaid commissions from 1971-1974. The NLRC affirmed the decision with minor modifications. Egyptair and Ezzat elevated the case via certiorari, arguing Joseph was a managerial employee whose dismissal without prior Ministry of Labor clearance was legal, that his role as Marketing Adviser transformed the relationship into a consultancy, and that his claim for unpaid commissions had prescribed.

ISSUE

The core issues were: (1) Whether an employer-employee relationship existed, making Joseph’s dismissal illegal; (2) Whether Joseph’s monetary claims, particularly for unpaid commissions, had prescribed.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC decision. On the first issue, the Court upheld the factual findings of the Labor Arbiter and NLRC that Joseph was a non-managerial employee. The Court emphasized that such factual determinations are binding unless grave abuse of discretion is shown, which was absent. The claim of abandonment was rejected. The evidence showed that as a Marketing Adviser, Joseph’s duties required him to work outside the office to solicit business. Furthermore, Egyptair’s own act of paying his salary from January to April 1974 contradicted the assertion of abandonment, and his prompt filing of a complaint negated any intent to sever employment.
On the second issue, the Court ruled that Joseph’s money claims did not prescribe. Petitioners argued the claim for 1971-1974 commissions should have been filed within one year from the date each annual claim accrued. The Court clarified that Article 292 (now Article 291) of the Labor Code provided a one-year prescriptive period for money claims accruing prior to the Code’s effectivity, to be counted from November 1, 1974, the Code’s effective date. Joseph filed his complaint on May 22, 1974, well before this deadline. The Court held that adopting the petitioners’ interpretation would be prejudicial to labor and contrary to the Code’s mandate to resolve doubts in favor of workers. Thus, all awarded monetary claims were valid.