SUNACE INTERNATIONAL MANAGEMENT SERVICES INC. vs.

NLRC
G.R. No.161757; January 25, 2006
DOCTRINE:
“The theory of imputed knowledge ascribes the knowledge of the agent to the
principal not the other way around.”
Facts:
Montehermozo was deployed as a domestic helper in Taiwan by petitioner Sunace with
the assistance of Wang, a Taiwanese broker for 12-months. After her contract with her
Taiwanese employer, she continued to work there for two years. After returning, she filed a
complaint with the NLRC against the petitioner, the Taiwanese broker, a certain Perez and her
employer since allegedly, she was imprisoned for three months and was underpaid. The Labor
Arbiter ruled in favor of Montehermozo and rejected Sunace’s contention that the extension
made was without its consent. On appeal with the NLRC, the LA’s decision was upheld. The
Court of Appeals likewise affirmed the decision of the labor tribunals.
Issue:
Is Sunace liable?
Held:
No. The theory of imputed knowledge ascribes the knowledge of the agent, Sunace, to
the principal, employer Xiong, not the other way around. There being no substantial proof that
Sunace knew of and consented to be bound under the 2-year employment contract extension, it
cannot be said to be privy thereto. As such, it and its "owner" cannot be held solidarily liable for
any of Divina’s claims arising from the 2-year employment extension. Furthermore, 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.