Title
G and P Manpower Services vs. National Labor Relations Commission
Case
G.R. No. 87644
Decision Date
Apr 20, 1992
In the case of G & P Manpower Services v. National Labor Relations Commission, the Supreme Court reverses the decision of the NLRC and reinstates the dismissal of the case by the POEA, ruling that the requirement of verification of position papers does not apply in proceedings before the POEA and that the lack of verification is a formal defect.
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Case Digest (G.R. No. 87644)

Facts:

  • The case is G & P Manpower Services v. National Labor Relations Commission, G.R. No. 87644, decided on April 20, 1992.
  • Orlando S. Jimenez and Armando S. Jimenez filed a complaint against G & P Manpower Services on August 11, 1986, for breach of contract, delayed salary payments, and damages.
  • The complainants were employed as a Road Foreman and a Paver Operator with defined monthly salaries.
  • Upon arrival in Saudi Arabia, they were compelled to sign a new contract that significantly reduced their salaries.
  • They reported poor working conditions and excessively long hours, prompting their resignation and return to the Philippines at their own cost.
  • The POEA dismissed the case for lack of merit on August 3, 1987.
  • The NLRC reversed this dismissal on December 22, 1988, holding G & P Manpower Services and Shibh Al-Jazira Contracting Establishment jointly liable.
  • The NLRC criticized G & P Manpower Services for submitting a position paper without proper verification.
  • G & P Manpower Services subsequently sought relief from the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of G & P Manpower Services, reversing the NLRC's decision and reinstating the POEA's dismissal.
  • The Court determined that the lack of verification was a formal defect, not a substantial one, and did not justify case dismissal.
  • The evidence presen...(Unlock)

Ratio:

  • The Court differentiated between formal and substantial defects in procedural requirements.
  • Verification of position papers is only mandated in proceedings before Labor Arbiters, not in POEA cases, where only the...continue reading

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