Title
Agoy vs. National Labor Relations Commission
Case
G.R. No. 112096
Decision Date
Jan 30, 1996
Overseas worker illegally dismissed after refusing reduced salary; Supreme Court ruled in his favor, awarding unpaid wages, voiding coerced settlement.
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Case Digest (G.R. No. 112096)

Facts:

Employment Contract and Deployment

Petitioner Marcelino B. Agoy applied for overseas employment as a civil engineer with private respondent Eureka Personnel Management Services, Inc. (EUREKA). He was accepted to work as a "CE/Road Engineer" for private respondent Al-Khodari Establishment (AL-KHODARI) under a two-year contract with a basic salary of SR1,750.00 per month, a food allowance of SR200.00, and free accommodation. On January 28, 1990, petitioner was deployed to Jubail, Saudi Arabia, but the Exit Pass mistakenly listed his employer as Belleli Saudi Heavy Industries Ltd. and his position as "Foreman" with a basic monthly salary of US$460.00, which differed from the original contract.

Change in Position and Salary

Upon arrival, petitioner was deployed as a "Road Foreman" instead of a "CE/Road Engineer." He was later asked to sign a new contract with a reduced salary of SR1,200.00 or face termination and repatriation. Petitioner refused to sign the new contract, leading to his dismissal on March 26, 1990. He executed a Final Settlement releasing respondent Al-Khodari from all claims and liabilities and was repatriated to Manila on April 6, 1990.

Complaint and Initial Rulings

Petitioner filed a complaint for illegal dismissal, claiming unpaid salaries for the unexpired portion of his contract, salary differentials, and damages. The Philippine Overseas Employment Administration (POEA) dismissed the complaint, finding that petitioner voluntarily consented to his termination. On appeal, the National Labor Relations Commission (NLRC) reversed the POEA's decision, ruling in favor of petitioner and awarding him SR39,674.00 for unpaid salaries. Both parties filed motions for reconsideration, and the NLRC ultimately reinstated the POEA's decision, dismissing petitioner's complaint.

Issue:

  1. Whether petitioner was illegally dismissed from his employment.
  2. Whether petitioner voluntarily consented to his termination and executed the Final Settlement and Letter of Termination under duress.
  3. Whether the NLRC committed grave abuse of discretion in reversing its earlier decision and reinstating the POEA's dismissal of the complaint.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court reinstated the NLRC's December 9, 1992 decision, holding that petitioner was illegally dismissed and entitled to unpaid salaries. The Court emphasized the importance of protecting employees' rights, particularly in cases involving quitclaims and releases executed under duress.


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