Knowledge of agent imputed to the principal
SUNACE INTERNATIONAL MANAGEMENT SERVICES, INC. v.
NATIONAL LABOR RELATIONS COMMISSION et al.
G.R. No. 161757 Janua! "5, "##6
FACTS$ Respondent Divina Montehermozo is a domestic helper deployed to Taiwan
y Sunace !nternational Management Services "Sunace# under a $%&month
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 Montehermozo returned to the /hilippines, she 0led a complaint
against Sunace, *ang, and her Taiwanese employer efore the 1ational 2aor
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 2aor Ariter and Court of Appeals4 The 2aor Ariter ruled in favor
of Montehermozo and found Sunace liale thereof' The 1ational 2aor Relations
Commission and Court of Appeals a5rmed the laor ariter6s decision' -ence, the
0ling of this appeal'
!SS7)4 *hether or not there is theory of imputed (nowledge etween the
principal and the agent
-)2D4 18' As agent of its foreign principal, 9Sunace: cannot profess ignorance of
such an e+tension as oviously, the act of its principal e+tending 9Divina6s:
employment contract necessarily ound it,it too is a misapplication, a
misapplication of the theory of imputed (nowledge'
The theory of imputed (nowledge ascries the (nowledge of the agent, Sunace, to
the principal, employer .iong, not the other way around' The (nowledge of the
principal&foreign employer cannot, therefore, e imputed to its agent Sunace'
There eing no sustantial proof that Sunace (new of and consented to e ound
under the %&year employment contract e+tension, it cannot e said to e privy
thereto' As such, it and its ;owner< cannot e held solidarily liale for any of
Divina6s claims arising from the %&year employment 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 oligations arising from the contract are
not transmissile y their nature, or y stipulation or y provision of law'
Furthermore, 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'