Case Digest (A.M. No. P-18-3843 [Formerly OCA IPI No. 16-4612-P) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bienvenido M. Cadalin, et al. v. Philippine Overseas Employment Administration’s Administrator, et al. (G.R. Nos. 104776, 104911–14, 105029–32; Dec. 5, 1994), petitioners – Bienvenido M. Cadalin, Rolando M. Amul, Donato B. Evangelista and 1,767 fellow overseas contract workers represented by Atty. Gerardo A. Del Mundo – filed an amended class complaint on June 6, 1984 with the POEA seeking money claims against Asia International Builders Corporation (AIBC) as recruiter and Brown & Root International, Inc. (BRII) as employer. Their demands included unpaid wages for unexpired contract periods, interest on funds, overtime, holiday and leave differentials, premium pay, refund of SSS and tax contributions, retirement benefits, moral damages, attorney’s fees and injunctive relief. AIBC and BRII repeatedly sought bills of particulars and extensions, prompting petitioners to move for summary judgment and to declare respondents in default. After protracted hearings and interlocutory a Case Digest (A.M. No. P-18-3843 [Formerly OCA IPI No. 16-4612-P) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioners: Bienvenido M. Cadalin, Rolando M. Amul, Donato B. Evangelista, and 1,767 overseas contract workers, represented by Atty. Gerardo A. del Mundo and later by Atty. Florante M. de Castro.
- Respondents: Philippine Overseas Employment Administration (POEA) Administrator; National Labor Relations Commission (NLRC); Asia International Builders Corporation (AIBC, local recruiter); Brown & Root International, Inc. (BRII, foreign employer).
- Procedural History
- June 6, 1984: Amended complaint filed with POEA (Case No. L-84-06-555) for money claims (unpaid wages, benefits, premature repatriation damages) arising from projects in Bahrain, Saudi Arabia, UAE, Libya, Indonesia, Malaysia (1975–1983). Three related POEA cases (L-85-10-777, L-85-10-779, L-86-05-460) were consolidated.
- Appeals and motions before POEA and NLRC over defaults, bills of particulars, evidentiary submissions, and jurisdictional questions.
- Sept. 2, 1991 NLRC Resolution: modified POEA decision, awarded benefits to 149 claimants, dismissed others, and remanded claims of 683 and 69 claimants for further hearings.
- Mar. 24, 1992 NLRC denied all motions for reconsideration.
- Dec. 5, 1994: Supreme Court dismissed Rule 65 petitions (G.R. Nos. 104776, 104911–14, 105029–32).
Issues:
- Prescription
- Which prescriptive period governs: Bahrain law (1 year), Philippine Civil Code (10 years), or Labor Code (3 years)?
- Choice of Law and Contract Interpretation
- Whether Amiri Decree No. 23 of Bahrain is incorporated into the overseas-employment contracts as a matter of law.
- Class Suit
- Whether the consolidated labor cases qualify as a class suit under Rule 3, Sec. 12 (common interest and impracticability of joinder).
- Administrative Due Process and Proceedings
- Whether petitioners’ right to speedy disposition was violated by delays in POEA/NLRC.
- Whether AIBC/BRII should have been declared in default.
- Whether NLRC erred in admitting evidence after submission and in adjudicating claims itself instead of remanding to POEA.
- Remand of Claims
- Whether NLRC had authority under Art. 218(c) of the Labor Code to direct new hearings for claims dismissed for lack of proof.
- Miscellaneous
- Validity of compromise agreements, attorney’s lien claims, and admissibility of offers of compromise.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)