Case Digest (G.R. No. 77970)
Facts:
The case involves Ambraque International Placement & Services (petitioner) and Ruben J. Gandia (private respondent), with the National Labor Relations Commission (NLRC) and the Philippine Overseas Employment Administration (POEA) as respondents. The petitioner is a manpower recruitment agency based in Ermita, Manila, engaged in recruiting Filipino workers for employment in Saudi Arabia, specifically for the Al-Jazirah Al-Arabia Co., Ltd. Gandia was hired as a heavy equipment driver with a two-year contract and a monthly salary of $300. He left for Saudi Arabia on February 24, 1983, and arrived on February 26, 1983. However, just five days later, on March 4, 1983, he was repatriated to the Philippines.
Upon his return, Gandia filed a complaint with the POEA against the petitioner and its principal for breach of contract, claiming that he was dismissed without cause after requesting better living conditions due to unsanitary accommodations. The petitioner countered that ...
Case Digest (G.R. No. 77970)
Facts:
Background of the Case
- Petitioner: Ambraque International Placement & Services, a manpower recruitment agency based in Ermita, Manila, engaged in recruiting Filipino workers for employment in Riyadh, Saudi Arabia. Its principal is Al-Jazirah Al-Arabia Co., Ltd.
- Private Respondent: Ruben J. Gandia, a heavy equipment driver with prior work experience in Saudi Arabia, recruited by the petitioner for a two-year contract with a monthly salary of U.S. $300.00.
Employment and Repatriation
- Gandia left for Saudi Arabia on February 24, 1983, and arrived on February 26, 1983.
- On March 4, 1983, he was repatriated to the Philippines, just five days after arriving at the job site.
- Gandia alleged that he and other workers were provided unsanitary living quarters. He requested better accommodations, which led to his repatriation.
Complaint and Counterclaim
- On March 22, 1983, Gandia filed a complaint with the Philippine Overseas Employment Administration (POEA) against the recruitment agency and its principal for breach of contract, seeking payment of wages for the contract period.
- The petitioner countered that Gandia was dismissed for displaying arrogance, stubbornness, and belligerence. They also claimed Gandia owed the agency P1,000.00, supported by a promissory note and telex messages from the principal.
Telex Messages
- The first telex (February 27, 1983) stated Gandia was "unsuitable for work" and should be repatriated.
- The second telex (March 2, 1983) advised the agency to send only new recruits, as workers with prior Saudi Arabian experience caused problems.
POEA Decision
- On June 17, 1986, POEA Deputy Administrator Cresencio M. Siddayao ruled that Gandia’s dismissal was illegal. He found that Gandia was terminated for requesting better living conditions, not for misconduct.
- The POEA ordered the recruitment agency and its principal to pay Gandia the peso equivalent of U.S. $7,200.00 (less P1,000.00 for the counterclaim) and attorney’s fees.
NLRC Decision
- The petitioner appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal on January 30, 1987, affirming the POEA’s decision.
Issue:
- Whether Gandia’s dismissal was legal.
- Whether the recruitment agency should be held solidarily liable with its principal for the illegal dismissal.
- Whether the NLRC committed grave abuse of discretion in upholding the POEA’s decision.
Ruling:
- The Supreme Court dismissed the petition for lack of merit, affirming the NLRC’s decision.
- The Court held that Gandia’s dismissal was illegal, as the petitioner failed to provide sufficient evidence to justify the termination.
- The recruitment agency was held solidarily liable with its principal under Section 10, Rule V of the Implementing Regulations of the Labor Code.
- The Court found no grave abuse of discretion on the part of the NLRC.
Ratio:
- Illegal Dismissal: The petitioner’s allegations of Gandia’s misconduct were unsupported by specific evidence. The telex messages were too general and did not establish just cause for termination. Gandia’s request for better living conditions was a legitimate concern and did not warrant dismissal.
- Solidary Liability: Under the Labor Code’s Implementing Regulations, recruitment agencies are jointly and solidarily liable with their principals for violations of employment contracts.
- No Grave Abuse of Discretion: The NLRC’s decision was based on substantial evidence and consistent with the law. The Court found no reason to overturn it.