G.R. No. 229984 - Jacob vs. 1st Step Manpower International Services, Inc.

Donna B. Jacob (petitioner), a Filipina, applied for a household service worker position with First Step Manpower International Services, Inc. (respondent agency).
She signed a two-year contract for deployment to Riyadh, Kingdom of Saudi Arabia (KSA), with a monthly salary of US$400.00.
Jacob was deployed overseas on January 11, 2015, and was brought to the residence of her foreign employer Abdulaziz Masser Abdulaziz Al Masoud.

Around noon on January 31, 2015, Jacob was washing dishes when her male employer allegedly attempted to rape her.
She reported the incident to her female employer, who disbelieved her and subsequently maltreated her.
On February 16, 2015, the female employer hit her with a shoe and threw it at her violently.
Fearing for her safety, Jacob escaped to the agency’s counterpart office in Riyadh, where she met another Filipino worker, Rosalie Bermido, who shared similar experiences of maltreatment and warned her about being sold to Arab employers.
Suggested escape route was through the window of a second-floor comfort room since the agency doors were locked at night. Bermido escaped successfully, but Jacob fell and sustained a spinal injury.
A passerby harassed them sexually after her fall; they begged for medical assistance.
Jacob was hospitalized at King Saud Medical City and underwent surgery on February 28, 2015.
The Overseas Workers Welfare Administration (OWWA) representatives later took Jacob to a shelter in the Philippines while awaiting exit visa processing.

On March 25, 2015, Jacob executed a Final Settlement and Certification before the Labor Attaché at the Philippine Embassy in Riyadh, which:

Acknowledged she received all salaries and benefits.
Expressed voluntary agreement to be repatriated.
Waived the right to file complaints against employer and agency in KSA or the Philippines.

The settlement was stamped and “seen and noted” by Labor Attaché Rustico S.M. Dela Fuente.
Jacob was repatriated on March 31, 2015.

On July 2, 2015, Jacob and Bermido filed complaints before the Labor Arbiter for:

Respondents included First Step agency, its President Elnor Tapnio, and foreign employer Muhammad/Abdulaziz.
Jacob filed an amended complaint and pursued the case alone after Bermido’s complaint was dismissed for lack of prosecution.
Jacob denied signing the Final Settlement and Certification, alleging forgery.
Respondents asserted Jacob voluntarily pre-terminated the contract due to homesickness and executed the Final Settlement voluntarily. They denied maltreatment, sexual harassment, and nonpayment of salaries.

The Labor Arbiter ruled Jacob was constructively dismissed due to hostile working conditions, disregarded the Final Settlement’s validity, and awarded unpaid salaries for the unexpired contract, dismissing other claims for lack of merit.
The National Labor Relations Commission (NLRC) reversed the Labor Arbiter, holding the Final Settlement and Certification valid and dismissing Jacob’s complaint. The majority emphasized the presumption of regularity of official acts.
Commissioner Nograles dissented, concurring with the Labor Arbiter that Jacob was constructively dismissed, highlighting disbelief of the settlement’s voluntariness and the unbearable working conditions detailed by Jacob.
The Court of Appeals dismissed Jacob’s Petition for Certiorari, finding her allegations unsubstantiated and affirming the Final Settlement’s validity. It noted inconsistencies in Jacob’s narration and lack of report to authorities abroad. The ruling was upheld upon denial of her Motion for Reconsideration.

Jacob filed a Petition for Review on Certiorari before the Supreme Court praying for reversal of the Court of Appeals decision and reinstatement of the Labor Arbiter’s Decision.
Petitioner emphasized substantiation of maltreatment via affidavit and medical summary, and claimed the Final Settlement was a coercive “mere scrap of paper.”
Respondents maintained Jacob failed to prove maltreatment and resigned voluntarily, supported by the settlement and certifications of public officers.
Jacob replied stressing employer’s burden of proof and the lack of jurisdiction of the Philippine Embassy over illegal dismissal issues, alleging coercion to sign the settlement for repatriation.

Whether Jacob was constructively dismissed from her overseas employment.
Whether the Final Settlement and Certification executed abroad are valid and binding.
Whether Jacob voluntarily resigned or was forced to abandon her employment due to maltreatment.
Whether petitioner is entitled to moral, exemplary damages, attorney’s fees, and salary for the unexpired portion of the contract.