- Petitioner
- Cb Richard Ellis Philippines
- Respondent
- Daniel Paul Lynch
- Citation
- G.R. No. 256180
- Court
- Supreme Court
- Division
- First Division
- Decided
- September 14, 2021
Summary
CB Richard Ellis Philippines hired Daniel Lynch in 2012, promoting him to Manager in 2014 with a contract containing non-compete clauses and liquidated damages provisions. When Lynch resigned in 2016 with insufficient notice and allegedly joined competitor KMC MAG Group, the company withheld his final pay, 13th month pay, and commissions totaling P187,392.86 to offset claimed liquidated damages of P425,000. The Supreme Court ruled that employers cannot withhold wages to offset liquidated damages claims, as such damages do not constitute 'debt' under Civil Code Article 1706. The Court found insufficient proof of non-compete violation and ordered full payment of withheld wages plus nominal damages, attorney's fees, and 6% interest, affirming the Labor Arbiter's original decision through all appellate levels.