Maneja vs.

NLRC
G.R. 124013

June 5, 1998

Topic: Company Policies as an informal source of labor law

Facts: Maneja (employee) worked for Manila Midtown Hotel(MMH) (employer) as a telephone operator.
Maneja was dismissed by MMH due to violation of their company policy on culpable negligence
negligence or failure to follow specific instruction(s) or established procedure(s). Maneja filed a complaint
for illegal dismissal against MMH. Labor Arbiter Oswald Lorenzo ruled in favor of Maneja. Lorenzo noted
that on the face of the complaint, the issue revolves around the implementation and interpretation of
existing company policies, and as such it is within the jurisdiction of the grievance procedure under the
CBA between MMH and NUWRAIN (the Union in which Maneja is a member), but he still assumed
jurisdiction over the case since termination cases is within his jurisdiction.
Issue: Does the Labor Arbiter have jurisdiction over the case?
Ruling: Yes. Since there has been an actual termination, the matter falls within the jurisdiction of the
Labor Arbiter. The dismissal of Maneja does not call for the interpretation or enforcement of company
personnel policies but is a termination dispute which comes under the jurisdiction of the Labor Arbiter.
It should be explained that company personnel policies are guiding principles stated in broad, longrange terms express the philosophy or beliefs of an organizations top authority regarding personnel
matters. They deal with matters affecting efficiency and well-being of employees and include, among
others, the procedure in the administration of wages, benefits, promotions, transfer and other personnel
movements which are usually not spelled out in the collective agreement. The usual source of grievances,
however, are the rules and regulations governing disciplinary actions.