Case Digest (G.R. No. 179792)
Facts:
Respondent Armando C. Padua, Jr. filed a sworn statement before the POEA on January 6, 2003, charging petitioner LNS International Manpower Services (LNS) with violations of Section 2(b), (d), and (e), Rule I, Part VI of the 2002 POEA Rules for, among others, non-issuance of official receipt and misrepresentation in relation to his recruitment for employment in Saudi Arabia. Padua alleged that he paid LNS P15,000.00 as processing fees, P6,000.00 for medical expenses, and P1,000.00 for a trade test, but he was not issued receipts.
LNS admitted that Padua applied but stated that he withdrew his documents on July 27, 2002, submitting a withdrawal letter signed by Padua; LNS denied endorsing Padua to another agency, and it maintained that it had no role after the withdrawal. The POEA found LNS liable but absolved Sharikat Al Saedi International Manpower for insufficiency of evidence; the DOLE affirmed; the CA likewise affirmed and denied reconsideration.
Issues:
- Whether petitioner LNS International Manpower Services was liable for non-issuance of receipt and misrepresentation despite its claim of Padua’s prior withdrawal of application documents.
Ruling:
The Supreme Court granted the petition, reversed and set aside the CA decision and resolution, and dismissed the complaint against LNS for lack of merit. It also ordered the refund of the appeal bond amounts of P40,000.00 and P80,000.00.
Ratio:
The Court held that respondent’s allegations were self-serving and unsubstantiated, and thus lacked probative value, especially when petitioner’s evidence showed Padua’s withdrawal letter with undisputed due execution and Padua’s admitted signature. The Court found it illogical for LNS to allow the withdrawal and require a withdrawal form if LNS intended to endorse Padua’s papers to Sharikat.
Further, the Court found no basis for the conclusion that LNS endorsed Padua to Sharikat, since no proof was presented other than Padua’s bare claim. It also noted that Padua did not appeal the POEA ruling absolving Sharikat, making that determination final as to him; given the absence of evidence of payment to LNS or endorsement by LNS, the charges against LNS could not prosper.
Doctrine:
- Bare and unsubstantiated allegations do not constitute substantial evidence and have no probative value.
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