Case Digest (G.R. No. 104776)
Facts:
Bienvenido M. Cadalin, et al., G.R. No. 104776; G.R. Nos. 104911-14; G.R. Nos. 105029-32, December 05, 1994, Supreme Court First Division, Quiason, J., writing for the Court. Petitioners are hundreds of former overseas contract workers (OCWs) who filed multiple complaints before the Philippine Overseas Employment Administration (POEA) against Asia International Builders Corporation (AIBC) (local recruiter/contractor) and Brown & Root International, Inc. (BRII) (foreign employer), seeking money claims and benefits allegedly due under their overseas employment contracts and under Bahrain’s Amiri Decree No. 23 (Labor Law). POEA consolidated several cases (POEA Case Nos. L-84-06-555, L-85-10-777, L-85-10-779 and L-86-05-460). After hearings and extensive submissions, the POEA Administrator rendered a decision on January 30, 1989 awarding $824,652.44 in favor of 324 complainants and denying other claims for lack of proof.Respondents AIBC and BRII appealed to the National Labor Relations Commission (NLRC). On September 2, 1991 NLRC modified the POEA decision: it dismissed some claims as prescribed, ordered payment to 149 claimants, set aside awards for 19 claimants who worked outside Bahrain, and remanded the claims of groups of claimants to a Labor Arbiter for additional hearings (annexes A–E identified various claimants). NLRC applied Article 291 of the Labor Code (three-year prescription), limited the Bahrain law’s applicability to those who actually worked in Bahrain, found BRII jointly liable with AIBC, and found some POEA procedures defective. Motions for reconsideration were denied by NLRC on March 24, 1992.
Multiple Rule 65 petitions were then filed in the Supreme Court: G.R. No. 104776 (petitioners represented by Atty. Gerardo A. Del Mundo) sought among other reliefs to modify the NLRC resolution, declare respondents in default, treat the cases as a class suit, reverse NLRC’s prescription ruling, and sanction counsel; G.R. Nos. 104911-14 (petitioners represented by Atty. Florante M. De Castro) challenged NLRC’s application of a three-year prescription and denial of a “three-hour daily average” overtime formula; and G.R. Nos. 105029-32 (AIBC/BRII as petitioners) sought reversal of NLRC insofar as it granted claims to 149 claimants and ordered hearings for others. The petitions were consolidated in the Court.
During the Supreme Court proceedings many claimants entered into various compromise agreements with the employers; motions for approval of those settlements were filed and acted upon. Contentions over attorney’s liens and alleged improper representation led to motions to strike, notices to enforce charging lien, and accusations of contempt and unethical conduct between competing counsel. The Solicitor General filed a comment favoring NLRC’s three-year prescription view but suggesting the Bahrain one-year might apply; parties also disputed admissibility of Bahrain documents and the legal characterization of foreign statutes of limitati...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion by applying a three-year prescriptive period under Article 291 of the Labor Code instead of the ten-year prescriptive period of Article 1144 of the Civil Code or the one-year prescription of Bahrain’s Amiri Decree No. 23?
- Were petitioners denied the constitutional right to a speedy disposition of their cases, and should the POEA Administrator or NLRC have declared respondents in default and rendered summary judgment?
- Could the labor cases properly be maintained as a class suit (joinder of all 1,767 claimants)?
- Was the NLRC’s acceptance and application of Bahrain’s Amiri Decree No. 23 (and incorporation of its terms into employment contracts) and its remand order for additional hearings consistent with due process and NLRC’s authority?
- Were the compromises submitted and approved by the Court subject to enforcement-related challenges (attorney’s lien, alle...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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