Case Digest (G.R. No. 140495) Core Legal Reasoning Model
Facts:
The case of G & M (Phils.), Inc. vs. Epifanio Cruz (G.R. No. 140495) revolved around labor disputes stemming from the employment of Epifanio Cruz, who was recruited by G & M (Phils.), Inc. as a trailer driver for its foreign principal, Salim Al Yami Est., with an agreed salary of US$625 monthly, commencing on June 6, 1990. Upon arrival in the Kingdom of Saudi Arabia, Cruz alleged that he was compelled to sign an employment contract in blank, leading to a subsequent reduction of his salary to SR604.00. After approximately seven months of work, on December 28, 1990, Cruz was deported. He contended that the reasons for his termination involved complaints regarding substandard working conditions, non-payment of wages, overtime pay, salary deductions, and a change of employer. Consequently, Cruz initiated a complaint against G & M (Phils.), Inc., arguing for illegal dismissal, underpayment, and seeking reimbursement for transportation expenses. He claimed to have only re
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Case Digest (G.R. No. 140495) Expanded Legal Reasoning Model
Facts:
Petitioner G & M (Phils.), Inc. recruited respondent Epifanio Cruz as a trailer driver for its foreign principal, Salim Al Yami Est., under an agency-worker agreement effective June 6, 1990, with a stipulated monthly salary of US$625 for a two‑year period. Upon his arrival in Saudi Arabia, respondent contends that he was made to sign an employment contract in blank and that his salary was reduced to SR604.00. After working for seven months, he was deported on December 28, 1990, with his dismissal allegedly prompted by his complaints about sub‑human working conditions, non‑payment and underpayment of wages and overtime, unauthorized salary deductions, and a change of employer.Subsequently, respondent filed a complaint before the Labor Arbiter seeking relief for illegal dismissal, non‑payment and underpayment of wages, and refund of transportation expenses, alleging payment equivalent to only five months’ salary with two months completely unpaid. Among the evidence, respondent submitted a pay slip indicating his basic salary as SR604.00. Petitioner, on the other hand, argued that respondent abandoned his job by joining an illegal strike, thereby constituting a breach of contract justifying his termination, and questioned the authenticity and admissibility of the pay slip since no original copy was presented.
The Labor Arbiter found merit in petitioner's contention of job abandonment but nonetheless ruled in favor of respondent regarding underpayment of wages and the unpaid two months, ordering G & M (Phils.), Inc. to pay the salary differential and unpaid wages. The NLRC, on partial appeal, dismissed petitioner's appeal for lack of merit and upheld the award, holding both petitioner and Salim Al Yami Est. jointly and severally liable. A subsequent appeal to the Court of Appeals and a special civil action for certiorari in the CA were similarly dismissed, affirming the findings and orders of the lower bodies.
Issues:
- Whether the findings of the Labor Arbiter, the NLRC, and the Court of Appeals—that respondent was underpaid and did not receive his full salary as agreed—are supported by substantial evidence.
- Whether respondent’s admission of receiving some payments shifts the burden of proof onto him to demonstrate that such payments were in conformity with the stipulated salary.
- Whether petitioner’s failure to present evidence of full payment of the agreed monthly salary alleviates its responsibility, particularly in view of the established rule on the burden of proof regarding monetary claims.
- Whether the pay slip, as submitted by respondent, is admissible and sufficient to corroborate his claim of underpayment despite concerns over its authentication.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)