Case Digest (G.R. No. 77279)
Facts:
Manuela S. Catan/M.S. Catan Placement Agency, Petitioners, vs. The National Labor Relations Commission, Philippine Overseas Employment Administration and Francisco D. Reyes, Respondents, G.R. No. 77279, April 15, 1988, the Supreme Court Third Division, Cortes, J., writing for the Court.Petitioner is a licensed recruitment agency that, as agent of the Ali and Fahd Shabokshi Group (a Saudi employer), recruited private respondent Francisco D. Reyes to work in Saudi Arabia as a steelman under a one‑year contract dated May 15, 1981 to May 14, 1982 which contained an automatic‑renewal clause requiring one‑month prior notice to terminate. Petitioner facilitated the placement.
After the original term, the employment contract was automatically renewed when the worker was not repatriated but reassigned as a crusher plant operator. On March 30, 1983, while operating the crusher, Reyes suffered a crushed right ankle. He returned to the Philippines on May 15, 1983 (after the renewed term’s expiration), underwent surgery and incurred medical expenses, then returned to Saudi Arabia on September 9, 1983 to resume work and was finally repatriated on May 15, 1984, with further treatment and expenses incurred thereafter.
Relying on the contractual provision that the employer should compensate for injury or permanent disability incurred in the course of employment, Reyes filed a claim docketed as POEA Case No. 84‑09‑847 before the Philippine Overseas Employment Administration (POEA). On April 10, 1986 the POEA rendered judgment awarding disability benefits (P7,985.60), reimbursement of medical expenses (P29,096.20), and ten percent attorney’s fees. The National Labor Relations Commission (NLRC), on appeal, affirmed the POEA decision in a resolution dated December 12, 1986.
Petitioner filed a special civil action for certiorari in this Court, alleging grave abuse of discretion by the NLRC: (a) that the employment contract and the agency agreement had expire...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion in holding petitioner liable for disability benefits on the ground that the employment contract had already expired when the injury occurred?
- Did the NLRC commit grave abuse of discretion in affirming the award of medical expenses where the worker allegedly returned to Saudi Arabi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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