G.R. No. 82310 - Feagle Construction Corp. vs. Gayda

Petitioner: Feagle Construction Corporation (FCC), a licensed private recruitment agency.
Respondents:

Private Filipino workers employed by Algosaibi-Bison, Ltd. in Saudi Arabia (including, inter alia, Gavino Gayda, Elpidio Agpalaya, Miguelito Batoon, and others).
National Labor Relations Commission (NLRC), as the administrative body involved in the dispute.

The Filipino workers were deployed by FCC to work on construction projects in Saudi Arabia, having served between three to five years with the foreign principal employer, Algosaibi-Bison, Ltd.
In 1983, due to a significant drop in the price of oil, Algosaibi-Bison, Ltd. encountered severe financial difficulties, leading to delayed remittances of workers’ salaries and benefits.
Although payments for the years 1983 and 1984 were eventually made, they were subject to significant delays.
FCC advanced mobilization expenses (including passport, medical, and visa fees) out of its own funds and consistently urged the employer to prioritize worker payments.

In July 1984, about forty Filipino workers, including private respondents, met with FCC management requesting to be sent back to Saudi Arabia despite the known risks.
Workers were informed by FCC’s president, Florentino B. Aguila, about the financial risks of re-deployment given Algosaibi-Bison, Ltd.’s difficulties.
The workers insisted on returning to work despite unemployment in the Philippines, and in doing so, they agreed to sign a written waiver (Statement xxx) stating that they would not hold FCC liable for any delay or non-payment of their salaries or benefits by Algosaibi-Bison, Ltd.
After signing the waiver, the workers were redeployed and, consequently, entered into new contracts directly with Algosaibi-Bison, Ltd.
When Algosaibi-Bison, Ltd. went into bankruptcy in 1986, the workers filed their claims individually with the liquidator; FCC had no further role in the disbursement process.

On October 3, 1986, private respondents initiated a complaint with the Philippine Overseas Employment Administration (POEA) concerning unpaid wages/benefits.
FCC submitted its answer on December 2, 1986, noting that it had not received a copy of at least one of the respondents’ complaints.
POEA rendered a decision on July 20, 1987, favoring the claims of the private respondents.
FCC’s appeal was subsequently elevated to the National Labor Relations Commission.
On January 29, 1988, the NLRC issued a decision affirming the POEA ruling but with a modification exempting FCC’s officials (Florentino and Rene Aguila) from liability while holding FCC jointly and severally liable with Algosaibi-Bison, Ltd.
FCC filed motions for reconsideration (first on February 11, 1988, and then a supplemental motion on March 8, 1988), which were denied by the NLRC.
A temporary restraining order had been issued on September 12, 1988, with FCC posting a bond of P50,000.00, which later became a subject of the final disposition.

Whether Feagle Construction Corporation may be held jointly and severally liable with the foreign employer, Algosaibi-Bison, Ltd., for the unpaid claims of the private respondents.

Whether the individual waivers (Statement xxx) executed by the private respondents—agreeing not to hold FCC accountable for any delay or non-payment of salaries—are valid and effective in precluding FCC’s liability.
Whether the changed circumstances, including the workers entering into new contracts directly with Algosaibi-Bison, Ltd. and filing claims directly with the liquidator, alter FCC’s liability under the general rule imposed on licensed private recruitment agencies.