Knowledge of agent imputed to the principal
SUNACE SUNA CE INTE INTERN RNA ATION TIONAL AL MANA MANAGE GEME MENT NT SERV SERVIC ICES ES,, INC. INC. v. NATIONAL LABOR RELATIONS COMMISSION et al. G.R. No. 161757 Janua! 161757 Janua! "5, "##6 FACTS$ Respondent Divina Montehermozo is a domestic helper deployed to Taiwan y Su Sunac nace e !n !nte tern rnat atio ional nal Ma Manag nagem emen entt Se Serv rvic ices es "S "Sun unac ace# e# un unde derr a $% $%&m &mon onth th contract' Such employment was made with the assistance of Taiwanese ro(er )dmund *ang' After the e+piration of the contract, Montehermozo continued her employment with her Taiwanese employer -ang Rui .iong for another % years' *hen Mon *hen Monteh teher ermoz mozo o re retur turned ned to the /hi /hili lippi ppines nes,, she 0le 0led d a com compla plaint int against Sunace, *ang, and her Taiwanese employer efore the 1ational 2aor Relations Commission "12RC#' She alleges that she was underpaid and was 3ailed for three months in Taiwan' She further alleges that the %&year e+tension of her employment contract was with the consent and (nowledge of Sunace' Sunace, on the other hand, denied all the allegations' Ruling of the 2aor Ariter and Court of Appeals4 The 2aor Ariter ruled in favor of Montehermozo and found Sunace liale thereof' The 1ational 2aor Relations Commission and Court of Appeals a5rmed the laor ariter6s decision' -ence, the 0ling of this appeal' !SS7) !SS7)44 *het *hethe herr or not not ther there e is theo theory ry of imput imputed ed (now (nowle ledg dge e etw etwee een n the the principal and the agent -)2D4 18' As agent of its foreign principal, 9Sunace: cannot profess ignorance of such such an e+ten e+tensio sion n as oviou oviously sly,, the act of its its princi principal pal e+ten e+tendin ding g 9Divin 9Divina6s a6s:: empl employ oym ment ent contr ontrac actt nec necessar ssariily oun ound d it,it t,it too too is a misap isappl pliicati cation on,, a misapplication of the theory of imputed (nowledge' The theory of imputed (nowledge ascries ascries the (nowledge of the agent, Sunace, to the principal, employer .iong, not the other way around' The (nowledge of the principal&foreign principal&foreign employer cannot, therefore, e imputed to its agent Sunace' There eing no sustantial proof that Sunace (new of and consented to e ound under the %&year employment contract e+tension, it cannot e said to e privy there thereto to'' As such, it and its ;owner< owner< cannot cannot e held held solida solidaril rily y liale liale for any of Divina6s claims arising from from the %&year employment employment e+tension' e+tension' As the 1ew Civil Code provides, Contracts ta(e e=ect only etween the parties, their assigns, and heirs, e+cept in case where the rights and oligations arising from the contract are not transmissile y their nature, or y stipulation or y provision of law' law' Furthermor Furthermore, e, as Sunace correctly points out, there was an implied revocation of its agency relationship with its foreign principal when, after the termination of the
original employment contract, the foreign principal directly negotiated with Divina and entered into a new and separate employment contract in Taiwan' Article $>%? of the 1ew Civil Code provides The agency is revo(ed if the principal directly manages the usiness entrusted to the agent, dealing directly with third persons, thus applies'