Title
Aldovino vs. Gold and Green Manpower Management and Development Services, Inc.
Case
G.R. No. 200811
Decision Date
Jun 19, 2019
Workers hired for Taiwan jobs faced contract changes, unpaid overtime, and illegal dismissal. SC ruled in their favor, declaring a law clause unconstitutional and awarding damages, fees, and salary reimbursement.
A

Case Digest (G.R. No. 203335)

Facts:

  • Petitioners’ Employment with Respondents
    • Julita M. Aldovino and six co‐workers applied to Gold and Green Manpower Management and Development Services, Inc. (Gold and Green Manpower) for overseas work under foreign principal Sage International Development Co., Ltd.
    • They paid a ₱72,000 placement fee via E-Cash Paylite; upon arrival in Taiwan, passports were confiscated and they were made to sign a new piece‐rate contract.
    • They worked 13‐hour days, six days a week, at piece rates lower than their original fixed salary and without proper overtime premiums.
  • Procedural History
    • In January 2009, petitioners (except one) filed a complaint in Taiwan for unpaid wages; in March 2009 they entered a Compromise Agreement for NT$1.5 million and executed quitclaims.
    • They returned to the Philippines in July 2009 and filed before the Labor Arbiter claims for illegal dismissal, unpaid salaries, human trafficking, return of placement fees, and other damages.
    • The Labor Arbiter and NLRC dismissed illegal dismissal claims and denied further relief; on appeal, the Court of Appeals (CA) in September 2011 found illegal dismissal, set aside the compromise agreement’s bar, and awarded placement‐fee reimbursement plus salaries for “unexpired contracts or three months cap.”
    • Petitioners moved for reconsideration to remove the three‐month cap; in January 2012 the CA denied relief. Petitioners then escalated to the Supreme Court (SC) via Rule 45 petition.

Issues:

  • Whether the Taiwan Compromise Agreement and petitioners’ quitclaims bar their Philippine labor claims.
  • Whether petitioners were illegally dismissed without just cause or due process.
  • Whether petitioners are entitled to salaries for the unexpired portion of their contracts and full reimbursement of placement fees.
  • Whether the “three‐month for every year of unexpired term” cap in Section 7 of RA 10022 is constitutional and binding.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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