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 ...

Facts:

Parties and Background

• Petitioner: Ambraque International Placement & Services, a duly organized manpower recruitment agency under Philippine laws, engaged in recruiting Filipino workers for employment abroad, particularly in Riyadh, Saudi Arabia.
• Respondents:
• The National Labor Relations Commission (NLRC)
• The Philippine Overseas Employment Administration (POEA)
• Private Respondent: Ruben J. Gandia, a worker recruited as a heavy equipment driver.

Recruitment and Employment Arrangement

• The recruitment agency entered into an employment arrangement with the private respondent for a two-year engagement in Saudi Arabia, with a monthly salary of U.S. $300.00.
• The worker, who had prior experience in Saudi Arabia, was hired despite this previous employment history.
• The agency maintained an office in Ermita, Manila, while its principal in Saudi Arabia was the Al-Jazirah Al-Arabia Co., Ltd.

Deployment and Early Termination

• The private respondent departed for Saudi Arabia on February 24, 1983, arriving on February 26, 1983.
• Only five days later, on March 4, 1983, he was repatriated to the Philippines.

Complaint and Allegations

• On March 22, 1983, the private respondent filed a complaint with the POEA alleging breach of contract and seeking payment for the wages corresponding to the contract period.
• He contended that:
• The living quarters were unsanitary.
• He had requested more suitable accommodations from the employer, which led to his abrupt repatriation.
• His dismissal was without just cause and, therefore, illegal.

Petitioner’s Counterclaims and Evidence Submitted

• The recruitment agency (petitioner) asserted that:
• The private respondent was validly dismissed due to his display of arrogance, stubbornness, and belligerence toward his employer.
• His conduct compelled the principal to repatriate him.
• The worker incurred no recruitment expenses while he allegedly had an outstanding account amounting to P1,000.00.
• Supporting evidence included:
• Two telex messages from the foreign principal:
• First telex (dated February 27, 1983) indicating that “Mr. Ruben G. Gandia” was found unsuitable for work and should be returned, with flight ticket charges to be deducted from the total payment.
• Second telex (dated March 2, 1983) advising the local agent to send only new recruits, implicitly condemning workers with prior experience in Saudi Arabia.
• A promissory note executed by the private respondent in favor of the agency for the amount of P1,000.00.

POEA’s Decision and Subsequent Appeals

• In a Decision dated June 17, 1986, POEA Deputy Administrator Cresencio M. Siddayao ruled that:
• The dismissal was illegal since the primary cause was the worker’s request for better accommodations.
• The negative attributes cited by the petitioner were sweeping and lacked sufficient foundation.
• The foreign employer’s instruction, via telex, to accept only new recruits corroborated the conclusion that the dismissal stemmed from the worker’s complaints rather than genuine misconduct.
• The decision held the recruitment agency and its principal solidarily liable for:
• Payment of the peso equivalent of U.S. $7,200.00 for the full remuneration due, less the P1,000.00 counterclaim.
• Attorney’s fees.
• The petitioner appealed the decision before the NLRC (docketed as POEA Case No. L-251-83), arguing errors in the appreciation of facts and contending that joint liability should not attach to it.
• The First Division of the NLRC dismissed the appeal for lack of merit, a decision which was later upheld by the Court upon elevation via a Petition for certiorari filed on April 10, 1987.

Issue:

Legality of the Dismissal

• Whether the termination of the private respondent's employment was justified and based on sufficient evidence of misconduct.
• Whether the dismissal was, in fact, prompted solely by his request for improved living conditions.

Adequacy and Specificity of the Evidence

• Whether the telex messages and other submissions by the petitioner sufficiently established that the worker exhibited unsuitability, arrogance, stubbornness, and belligerence.
• Whether the evidence detailed the circumstances surrounding the alleged misconduct.

Solidary Liability and Recruitment Agency Responsibilities

• Whether the enforcement of joint and solidary liability against the recruitment agency under Section 10, Rule V of the Implementing Regulations of the Labor Code is proper.
• Whether the petitioner should be held liable alongside its foreign principal for the alleged breaches of the recruitment agreement.

Abuse of Discretion

• Whether the respondent Commission committed a grave abuse of discretion in upholding the POEA Deputy Administrator’s decision and dismissing the petitioner’s appeal.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)