2015 Labor Law, Q21

Philippine News Network (PNN) engages the services of Anya, a prominent news anchor from a rival station, National News Network (NNN). NNN objects to the transfer of Anya claiming that she is barred from working in a competing company for a period of three years from the expiration of her contract. Anya proceeds to sign with PNN which then asks her to anchor their nightly newscast. NNN sues Anya and PNN before the National Labor Relations Commission (NLRC), asking for a labor injunction. Anya and PNN object claiming that it is a matter cognizable by a regular court and not the NLRC.
(a) Is NNN’s remedy correct? Why or why not? (3%)
(b) What are the grounds for a labor injunction to issue? (2%)
(c) Distinguish the jurisdiction of a Labor Arbiter from that of the NLRC. (3%)

Quick check

Which tribunal has exclusive jurisdiction to enforce a post-employment non-compete restriction against a former employee?

Under Article 225(e) of the Labor Code, what is an essential prerequisite for the NLRC to issue a labor injunction?

How does the jurisdiction of a Labor Arbiter differ from that of the National Labor Relations Commission?

Why is National News Network's petition for a labor injunction before the NLRC against Anya and PNN improper?

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Which of the following falls under the exclusive original jurisdiction of a Labor Arbiter under Article 224 of the Labor Code?

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1. Non-Compete Clause Jurisdiction
Enforcement of a post-employment non-compete covenant is grounded on contract law and civil breach obligations rather than labor standards or relations disputes. Although the non-compete clause originates from an employment agreement, an action seeking damages or injunctive relief for its breach after employment termination falls under the exclusive original jurisdiction of regular civil courts rather than the National Labor Relations Commission. Where no employer-employee relationship or labor dispute exists at the time of enforcement, labor tribunals lack subject-matter jurisdiction to adjudicate the dispute or grant injunctive relief.

2. Labor Injunction Grounds
Under Article 225(e) of the Labor Code, a labor injunction is an extraordinary remedy issued only upon strict compliance with statutory requisites within a labor dispute. To justify a labor injunction, the complainant must establish that unlawful acts have been threatened or committed causing substantial and irreparable injury to property. Furthermore, it must be demonstrated that greater injury will be inflicted upon the complainant by denying relief than upon the defendants by granting it, that no adequate legal remedy exists, and that public officers are unable or unwilling to furnish adequate protection.

3. Tribunal Jurisdiction Compared
Labor Arbiters and the National Labor Relations Commission exercise distinct statutory jurisdictions under the Labor Code. Under Article 224, Labor Arbiters possess exclusive original jurisdiction over labor disputes, unfair labor practices, illegal dismissal cases, money claims, and legality of strikes. Conversely, the NLRC is primarily an appellate body exercising exclusive appellate jurisdiction over decisions rendered by Labor Arbiters. The NLRC possesses original jurisdiction only in limited, extraordinary matters expressly provided by law, such as petitions for certified labor injunctions and contempt proceedings arising from actual labor disputes.

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The questions reproduced here are the official texts of the Philippine Bar Examinations, published by the Supreme Court. They are reproduced for study purposes.The suggested answers are the author’s own.

They are not official answers, have no connection with the Supreme Court, the Office of the Bar Confidant, or any bar review institution, and are not endorsed by any of them. Official answer keys, where released, should be preferred over anything here.Nothing on this page is legal advice, and reading it creates no lawyer-client relationship. Do not rely on any suggested answer in an actual legal matter. Consult counsel on your own facts.Suggested answers reflect the law and jurisprudence the author considers applicable as of the date shown.

Where a question comes from an earlier examination, the suggested answer applies the law as it now stands, which may differ from the law in force when the question was given, and may therefore differ from what would have been the correct answer at that time. Where the difference is material, the answer notes it.The practice scoring feature measures wording overlap with the suggested answer. It is not a grade, carries no official weight, and says nothing about whether your reasoning is sound.Errors are possible. If you find one, please tell me and I will correct it.Last reviewed: October 2026