G.R. No. 203882 - Iladan vs. La Suerte International Manpower Agency, Inc.

Petitioner: Lorelei O. Iladan, a domestic helper who was deployed to work overseas in Hong Kong.
Respondents: La Suerte International Manpower Agency, Inc. (a recruitment agency duly authorized by the POEA) and its President and General Manager, Debbie Lao.

On March 20, 2009, La Suerte hired Iladan to work in Hong Kong as a domestic helper for a two-year term at a monthly salary of HK$3,580.00.
On July 20, 2009, Iladan was deployed to her principal employer, Domestic Services International, to serve Ms. Muk Sun Fan.

Roughly eight days into her employment (July 28, 2009), Iladan executed a handwritten resignation letter.
On August 6, 2009, in exchange for financial assistance amounting to P35,000.00 provided by Domestic Services International, Iladan signed an Affidavit of Release, Waiver and Quitclaim before Labor Attache Leonida V. Romulo at the Philippine Consulate General in Hong Kong.
On the same date, an Agreement was executed, involving Conciliator-Mediator Maria Larisa Q. Diaz and a representative of Domestic Services. By signing, Iladan acknowledged that the financial assistance would serve as full settlement of any contractual claims against respondents and Domestic Services.

On November 23, 2009, after returning to the Philippines on August 10, 2009, Iladan filed her complaint alleging illegal dismissal.
Her complaint further sought refund of the placement fee (claimed to be P90,000.00), wages corresponding to the unexpired portion of her contract, and moral and exemplary damages.
Iladan alleged that her resignation was not voluntary but was executed under duress—she claimed coercion, threats (including an alleged threat of incarceration), and that the documents she signed were not adequately explained to her in a language she understood.

Iladan produced a handwritten resignation letter and the consular-affiliated Affidavit of Release, Waiver and Quitclaim and Agreement as evidence of coercion, contending these documents were executed under duress.
To support her claim of payment of a placement fee, Iladan presented documents including a mortgage deed, a deed of transfer of rights, a sworn statement by her mother, and a demand letter from Nippon Credit Corp., Inc.
Respondents countered that Iladan voluntarily resigned as evidenced by these same documents and denied the collection of any placement fee, invoking the POEA rules that prohibit charging a placement fee for domestic helpers destined for Hong Kong.

The Labor Arbiter (Decision dated August 11, 2010) ruled that Iladan was illegally dismissed, finding that she was forced to resign, and awarded her monetary relief including wages for the unexpired portion of her contract (after deducting the P35,000.00 received), refund of the placement fee, moral and exemplary damages, and attorney’s fees.
On appeal, the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision in its Resolution dated February 23, 2011 and denied a subsequent motion for reconsideration on March 31, 2011.
The Court of Appeals (CA) reversed both the Labor Arbiter and NLRC decisions via its May 16, 2012 Decision and reaffirmed by its October 4, 2012 Resolution, holding that Iladan voluntarily resigned as substantiated by her resignation letter, the consular-authenticated affidavit and agreement, and by her acceptance of the financial assistance. The CA also found no credible evidence that a placement fee was paid.

Whether the Court of Appeals has the authority to review and reverse the factual findings of both the Labor Arbiter and the NLRC.
Whether Iladan’s resignation, as well as her execution of the Affidavit of Release, Waiver and Quitclaim and the Agreement, were made voluntarily.
Whether the financial assistance of P35,000.00 accepted by Iladan constituted a final settlement of her claims against the respondents.
Whether Iladan was, in fact, illegally dismissed or whether her resignation was voluntary.
Whether there is any credible evidence that Iladan paid a placement fee to the respondents.