G.R. No. 160123 - Centro Project Manpower Services Corp. vs. Naluis

Centro Project Manpower Services Corporation, a local recruitment agency, engaged Aguinaldo Naluis as a plumber to work abroad under Pacific Micronesia Corporation in Garapan, Saipan, Commonwealth of the Northern Mariana Islands (Northern Marianas).
The primary Employment Contract was executed on March 11, 1997, which provided for a 12‑month period of employment.
The contract stipulated that employment would commence upon the employee’s arrival abroad; however, an addendum executed on September 3, 1997, changed the effective start date to his departure from the point of origin.

On June 3, 1997, the Department of Labor and Immigration of the Northern Marianas issued an Authorization for Entry (AE) in Naluis’ favor.
The AE, while allowing entry, contained an expiration date (May 13, 1998) that Centro Project later relied on to justify repatriation.
Naluis departed for the Northern Marianas on September 13, 1997, which was his actual deployment date.

Although the contract provided for a 12‑month employment period, Naluis was repatriated on June 3, 1998, prior to completing the agreed term, allegedly because of the expiration of the contract as interpreted by the employer.
Feeling aggrieved by what he perceived as an illegal dismissal, Naluis filed a complaint for illegal dismissal.

The Labor Arbiter ruled that Naluis’ repatriation was not a dismissal but a necessary consequence of complying with the Commonwealth’s immigration rules as reflected in the AE.
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision, holding that the contract had expired in accordance with the AE and the established stipulations in the Employment Contract.

Naluis assailed the NLRC decision before the CA, arguing that the AE did not legitimately limit his stay nor justify his premature repatriation.
The CA ruled in favor of Naluis by setting aside the NLRC decision and ordering Centro Project to pay various money claims for breach of the 12‑month employment contract.
Specific awards included four months’ salary, placement fee, vacation leave pay, and sick leave pay, while excluding claims for guaranteed overtime and legal holiday pay, based on the terms of the contract.

Whether the expiration date indicated in the AE (May 13, 1998) validly limited Naluis’ period of employment or merely denoted the expiration of the document itself.
Whether Centro Project’s reliance on the AE to justify the repatriation was legally tenable.

Whether the 12‑month period stipulated in the primary Employment Contract was the controlling term in the absence of a clear and categorical limitation provided either in the AE or the contract.
The effect of the handwritten alteration (May 3, 1998) inserted in the contract after Naluis had signed it and its evidentiary value.

Whether any ambiguity or doubt in the provisions of the Employment Contract should be resolved in favor of the laborer, as mandated by the Labor Code and the Civil Code.

Whether Centro Project discharged its burden of proving that the repatriation of Naluis was justified under the terms of the contract and applicable law.