Marilyn B. Asentista v. Jupp & Company

Summary

Sales agent Marilyn Asentista claimed unpaid commissions totaling P210,077.95 from JUPP & Company after the company deducted unauthorized car plan payments from her earned commissions. The Labor Arbiter dismissed her claim citing lack of written commission agreement, but the NLRC reversed based on electronic evidence from the company president. The Court of Appeals reinstated dismissal, rejecting the electronic evidence. The Supreme Court ultimately ruled in Asentista's favor, holding that the employer admitted commission entitlement and that sales commissions constitute wages under Labor Code Section 97(f). The Court applied the principle that employers bear the burden of proving payment of monetary claims and found the unauthorized deductions violated unjust enrichment principles. The decision reinforced employee protection in commission-based compensation disputes and established clear employer obligations regarding deductions from employee benefits.