Case Digest (G.R. No. 112096)
Facts:
The case involves Marcelino B. Agoy as the petitioner and the National Labor Relations Commission (NLRC), Eureka Personnel Management Services, Inc., and Al-Khodari Establishment as respondents. The events leading to this case began when Agoy applied for overseas employment as a civil engineer with Eureka, which subsequently deployed him to work for Al-Khodari in Jubail, Saudi Arabia, under a two-year contract with a monthly salary of SR1,750.00 and a food allowance of SR200.00. However, upon his deployment on January 28, 1990, Agoy discovered that he was mistakenly issued an Exit Pass indicating a different employer and a lower position as "Foreman" with a reduced salary of US$460.00.
Agoy was compelled to accept this position and began work on February 7, 1990. Later, he was asked to sign a new contract with a further reduced salary of SR1,200.00, which he refused, leading to his dismissal on March 26, 1990. After receiving his final salary, he signed a Final S...
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:
- Whether petitioner was illegally dismissed from his employment.
- Whether petitioner voluntarily consented to his termination and executed the Final Settlement and Letter of Termination under duress.
- 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.