1. [G.R. NO. 154295.

July 29, 2005]

METROMEDIA TIMES CORPORATION vs. PASTORIN CASE DIGEST

METROMEDIA TIMES CORPORATION and/or ROBINA GOKONGWEI-PE,

Petitioners, VS. Johnny Pastorin, Respondent.

FACTS
Respondent was reportedly dismissed by the petitioner company for tardiness, but the
discharge was avoided by the union's quick intervention. The respondent, however,
commit another offense when, after receiving a loan from a magazine dealer and being
unable to repay the loan, he ceased collecting the dealer/creditor dues. After being
compelled to explain himself, the respondent admitted to not paying the loan but
provided no definitive justification. As a result, he was suspended. Despite the fact that
the suspension had expired, the respondent did not report for work and submitted a
letter stating his refusal to accept the transfer. He subsequently filed a case with labor
arbitration alleging constructive dismissal, nonpayment of wages, and other money
claims.
The appeal was decided in favor of the accused. The petitioner appealed to the NLRC
alleging that the labor arbitrator lacked jurisdiction over the defendant's complaint. It is
significant that the petitioner did not raise this issue in the labor arbitration tribunal
process. The NLRC overturned LA's decision, ruling that the dispute was fully visible to
the voluntary arbitrator and that LA had no jurisdiction over it. The CA, on the other
hand, reaffirmed the CA's decision. The CA concluded that the active participation of the
person against whom the claim is equivalent to an appeal to such jurisdiction and a
desire to adhere to the resolution of the case and will prevent that party from
challenging the court's or body's jurisdiction.
ISSUE
Whether or not petitioner can possibly challenge the LA's jurisdiction during the appeal?
RULING
The petitioner was not barred from contesting LA's jurisdiction during the appeals
process, according to the Supreme Court. As a general rule, the court's jurisdiction over
the case's subject matter is subject to a law that cannot be granted with the consent or
agreement of the parties. The incompetence of the court may be invoked at any stage
during the proceedings, including on appeal. Recent statements, have qualified this
theory, primarily based on the decision in the Sibonghanoy case. Unfortunately,
however, the ruling in this case applies to situations that are clearly not addressed. The
exceptional circumstances in Sibonghanoy, which justified deviating from the accepted
concept of not waiving a jurisdictional objection, were ignored, and instead a general
doctrine was repeatedly applied, effectively overturning the established principle that an
exception to jurisdiction must be lifted.
The application of the estoppel principle to a matter of jurisdiction seems to depend on
whether the lower court has jurisdiction. If it lacks jurisdiction but has declared and
concluded the case on that basis, the parties are not prohibited from challenging that
jurisdiction on appeal, as jurisdiction must exist by law and cannot be granted by the
parties' authorization or estoppel. If the lower court had jurisdiction and the case was
known and resolved on the basis of a particular theory, such as that the court lacked
jurisdiction, the party who persuaded the court to accept that theory could not be
permitted on the appeal, indicating that the lower court instance had jurisdiction. The
concept of estoppel applies in that situation.
In this case, the concept that jurisdiction is conferred by law rather than permission of
the parties makes no sense. In accordance with the basic rule that estoppel does not
grant jurisdiction, the petitioner is not barred from challenging the labor arbitration
tribunal's authority before the NLRC. The CA’s decision is revoked.

2. [G.R. NO. 229984. July 08, 2020]

DONNA B. JACOB VS. FIRST STEP MANPOWER INT’L SERVICES, INC. CASE
STUDY

DONNA B. JACOB, Petitioner, VS. FIRST STEP MANPOWER INT’L SERVICES,

INC., MUHAMMAD/ELNOR E. TAPNIO, Respondents.

FACTS
A Filipina's bravery in working as a type of domestic helper in a strange country
deserves much more than a superficial examination of the facts in file. Jacob has only
been abroad for less than three (3) months before being repatriated due to the following
oath claims she made. She said that her male boss attempted to rape her, but her
female boss did not believe her and instead mistreated her since then. February 16,
2015,  her female boss hit and throw her violently a shoes, so she fled and went to her
agency, where she encountered another OFW named Rosalie Bermido, who advised
her leave their agency. Bermido successfully escape, but Jacob wasn’t as she fell and
injured her spinal column. There was an Arab who spotted them, called the police, and
abused them. They begged the Arab to call for an ambulance, so they were transported
to a hospital where Jacob had surgery. After a few days, agents from the Overseas
Workers Welfare Administration transported them to Bahay Kalinga, where they awaited
their exit visas. Jacob went before the Office of the Labor Attaché on March 25, 2015,
and signed a Final Settlement and Certification, and has returned to the Philippines
upon March 31, 2015. Jacob and Bermido filed a case with the Labor Arbiter on July 2,
2015, alleging constructive illegal dismissal, mistreatment, and nonpayment of wages
for the unexpired term of their contract, as well as claims for moral and exemplary
damages, medical costs, and attorney's fees. Jacob insisted on being constructively
dismissed since her working environment reportedly got so intolerable that she was
forced to quit. She questioned the Final Settlement and Certification, claiming that the
claimed signature was not hers.
The Court of Appeals' inability to recognize the totality of the evidence supporting the
allegation of sexual harassment, mistreatment, and involuntary escape is definitely a
gross abuse of discretion that the Court must address. Constructive dismissal does not
always imply "outright dismissal or reduction in rank, salary, benefits, and privileges."
Contrary to popular belief, constructive dismissal can be used specifically in situations
where "an act of obvious discrimination, insensibility, or scorn on the part of an
employer becomes so unbearable on the part of the employee that it could effectively
prevent him or her from making any decision other than to resign from his or her current
work." Respondent contend that the petitioner did not present sufficient evidence to
support her allegations. The petitioner’s arguments show that all she wanted was for the
Court of Appeals' decision to be reversed "because she is destitute," as she claims.
Apart from her bold claims and erroneous belief in social justice, her petition has no
substantial evidence.
ISSUE
Whether or not the petitioner failing to offer sufficient evidence to support her allegations
can overturn the judgment of the Court of Appeals?
RULING
"An amount of relevant evidence that a reasonable mind would accept as adequate to
establish a decision, even if other equally reasonable minds disagree," according to the
definition of "substantial evidence."
Thus, as in the case at hand, where the petitioner's confirmed declaration revealing the
situation that caused her to leave her foreign employer's residence and thus forego
continued employment was supported by other documentary evidence such as crucial
medical documents, this Court "held that the substantiality of the evidence depends on
both its quantitative and qualitative aspects," as in the case at hand.

3. [G.R. NO. 200088. February 26, 2018]

PHILIPPINE AIRLINES, INC. VS. AIRLINE PILOTS ASSOCIATION OF THE

PHILIPPINES CASE STUDY
FACTS
The case arose from a labor dispute between the petitioner, Philippine Airlines, Inc.
(PAL), and the respondent, the Airline Pilots' Association of the Philippines (ALPAP),
which is a legally recognized labor organization that represents all of PAL's commercial
pilots. ALPAP filed a notice of strike with the Department of Labor and Employment
(DOLE) on December 9, 1997, claiming PAL's unfair labor practices. Despite the
SOLE's restraining order, ALPAP went on strike on June 5, 1998. On June 7, 1998, the
SOLE issued a return-to-work order7, but ALPAP refused and went on strike. As a
result, on June 1, 1999, the SOLE issued a resolution8 declaring the ALPAP strike
illegal and the officers who participated in it unemployed. The matter was eventually
heard by the Court. The Court rejected ALPAP's appeal in a Resolution10 dated 10
April 2002 for failing to prove that the CA engaged in a significant abuse of discretion or
made a reversible error. On August 29, 2002, the resolution became final. On April 22,
2003, more than eight (8) months after the Court's 10 April 2002 Resolution became
effective, PAL filed a complaint12 with the LA demanding damages against ALPAP and
some of its officers and members.
Three (3) PAL aircraft were abandoned on June 6, 1998, the second day of ALPAP's
illegal strike: (i) PR 730 meant for Paris, France, at Bangkok, Thailand; (ii) PR 741
bound for Manila, at Bangkok, Thailand; and (iii) PR 104 headed to Manila, at San
Francisco, California, USA. Passengers were stranded as a result of the flights'
purposeful and intentional cancellations, making PAL responsible for contract violation.
As a result, PAL was forced to pay for hotel accommodations, stranded passenger
meals, airport parking fees, and other operating costs. According to the airline, the
illegal strike also had an impact on PAL's operations, resulting in losses from ticket
refunds, unexpected closure expenditures, and lost revenue from canceled domestic
and international flights. According to the firm, the unlawful strike cost PAL
$73l,078,988.59. In addition, PAL sought for a $300,000 government grant.
ISSUE
Whether or not the NLRC and the labor arbitrator have jurisdiction over PAL's claims for
damages incurred as a result of the respondents' illegal strike-related conduct?
RULING
Labor tribunals hear claims for monetary compensation for damages incurred by a
strike. The Labor Code, as amended by Section 9 of R.A. No. 6715, delegated authority
to the LA and the NLRC over claims for damages arising from the employer-employee
relationship. Workers may file claims regarding earnings, rates of pay, hours of work,
and other employment circumstances and situations if they are backed by a claim for
reinstatement. Cases involving any breach of Article 264 of this Code, such as
challenges to the validity of strikes and lockouts; Any other claims originating from
employer-employee interactions, excluding claims for Workers' Compensation, Social
Security, Medicare, and maternity benefits. Civil disputes are heard in ordinary courts,
regardless of whether they include an employer's claim against its employees.
The labor arbitrator may legally examine the "reasonable connection test," which
stipulates that the claim for damages must have a reasonable causal link to any of the
claims permitted in that article. Only if the damage claim is linked to the other claims
can it be regarded the outcome of employer-employee interactions. The employer-
employee connection between the two parties is unrelated. As a result, the claim is only
subjected to the jurisdiction of regular courts. Article 217 of the Labor Code prohibits a
claim for damages if the employer-employee connection is only incidental and the action
is primarily civil in nature. The ruling of the appeals court was inaccurate. The court
agrees with PAL that its claim for damages is valid in light of the respondents' employer-
employee relationship. PAL's claim isn't based on a mere acts of quasi-delict. The
alleged losses resulted from the illegal strike and activities done during it, which were
closely associated to the respondents' accusations that PAL participated in unfair labor
practices. CA issued the following declarations: The damages caused by the striking
pilots' intentional act of abandoning their flights, together with the passengers and
cargo, causing harm to petitioner's company are recoverable under civil law. The
petitioner's claim for damages as a result of the illegal strike is heard in normal courts
rather than by the DOLE Secretary or the Labor Arbiter. Because the loss and harm for
which PAL wants compensation have a substantial causal relation with the alleged acts
of unfair labor practice, as stipulated for in Article 217 of the Labor Code, the matter of
damages becomes a labor disagreement and an employment relationship dispute.