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.
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Case Digest (G.R. No. 200811)

Facts:

Employment Application and Contracts:
Julita M. Aldovino and her co-petitioners applied for work at Gold and Green Manpower Management and Development Services, Inc., a local manning agency with a foreign principal, Sage International Development Company, Ltd. They were hired as sewers for Dipper Semi-Conductor Company, Ltd., a Taiwan-based company, with employment contracts stipulating an 8-hour workday, fixed monthly salary, and entitlement to overtime pay.

Placement Fees and Loan:
Before deployment, Gold and Green Manpower required each applicant to pay a ₱72,000 placement fee. Unable to pay, they were referred to E-Cash Paylite and Financing, Inc., where they loaned the amount.

Change in Contract Terms:
Upon arrival in Taiwan, their travel documents were confiscated, and they were made to sign a new contract paying them on a piece-rate basis instead of the agreed fixed monthly salary.

Working Conditions:
They worked from 8:00 a.m. to 9:00 p.m., six days a week, sometimes on Sundays without overtime pay. Due to the piece-rate system, they earned less than their contractual fixed salary.

Legal Actions:
On January 19, 2009, they filed a complaint in Taiwan for underpayment. After a meeting at the Bureau of Labor Affairs, they were ordered to return to the Philippines and were left at a train station in Taipei.

Compromise Agreement:
They entered into a Compromise Agreement with their employers, receiving monetary compensation and signing an Affidavit of Quitclaim and Release. They returned to the Philippines on July 28, 2009, and filed a case for illegal dismissal and other claims.

Labor Arbiter and NLRC Rulings:
The Labor Arbiter dismissed the illegal dismissal claim but ordered financial assistance. The National Labor Relations Commission (NLRC) affirmed the decision, stating the dismissal was not illegal and the Compromise Agreement barred further claims.

Issue:

  1. Whether the Compromise Agreement barred all other claims against the respondents.
  2. Whether the petitioners were illegally dismissed and entitled to reimbursement of placement fees, moral and exemplary damages, and attorney’s fees.
  3. Whether the clause "or for three (3) months for every year of the unexpired term, whichever is less" in Section 7 of Republic Act No. 10022 is constitutional.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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