G.R. No. 78993 - Miguel vs. National Labor Relations Commission

Petitioner Antonio P. Miguel was appointed personnel officer by First Holding International, Inc. (private respondent) on November 26, 1982 for the latter’s electrification project in Hail, Saudi Arabia.
Private respondent sent petitioner to its overseas project in Saudi Arabia after he rendered service at the Makati office.
Private respondent required petitioner to render service at the Makati office prior to deployment overseas.

On January 25, 1983, petitioner signed an employment contract for a period of twenty-four (24) months effective from the date of his departure, with a monthly base salary of U.S.$800.00.
On April 3, 1983, while petitioner was performing his job at the Al Jifah campsite, he was served a memorandum dated March 29, 1983, signed by project manager Oscar C. Guevarra and Deputy Project Manager Guillermo Santos, stating:

Appraisal/evaluation showed petitioner did not meet company standards for his incumbency from January 26, 1983 to present.
His probationary employment was terminated.
Processing of his Exit Visa, Plane Tickets, and other travel papers for repatriation was being expedited.

Petitioner questioned the memorandum, but no answer was given.
Petitioner was asked to pack his clothes, was taken out of the campsite, and was brought to the Hail Liason Office.
At the Hail Liason Office, petitioner again invoked his right to due process and asserted he could only be terminated for just cause.
He questioned the characterization of his employment as probationary, but no explanation was given.
Petitioner requested to be allowed to call the labor attache at Jeddah by long-distance telephone, but the request was denied.
Petitioner’s IQAMA or work permit was confiscated, confining his movement to the Hail office premises.
On April 7, 1983, petitioner was transported overland on the company vehicle to Riyadh.
Petitioner requested permission to pass through the company’s Riyadh office, but the request was denied.
Instead, petitioner was brought directly to the airport, where he was given his passport and plane ticket and a letter to FHl-AVP/ComptrolIer, Mr. Mel Macalintal.
After arrival in Manila, petitioner reported to Mr. Macalintal on April 11, 1983, and he was told that all payments due him would be paid on April 15, 1983.
He was actually paid on April 18, 1983, but only after he was required to sign a quitclaim in favor of the company.

On July 27, 1983, petitioner filed a complaint with the National Labor Relations Commission (NLRC) for illegal dismissal and unfair labor practice against the private respondent.
In the NLRC case, the labor arbiter dismissed the complaint for lack of jurisdiction on January 11, 1984.
On the same date, petitioner filed another complaint with the Workers Assistance and Adjudication Office of the Workers Assistance and Adjudication Office of the Philippine Overseas Employment Administration (POEA) for illegal dismissal and for non-registration of contract with the MOLE, praying for backwages, reinstatement, and prosecution of the company for falsification of documents.
After the parties filed pleadings and position papers, the POEA Workers Assistance and Adjudication Office rendered a decision on April 21, 1986 with the following dispositive portion:

Ordered the private respondent to pay U.S. DOLLARS SEVENTEEN THOUSAND FOUR HUNDRED TWELVE AND 10/100 (US$17,412.10) or its equivalent in Philippine currency at the time of actual payment as salary corresponding to the unexpired portion of the employment contract.
No other pronouncement.

The private respondent appealed to the NLRC.
The NLRC, in a decision dated May 8, 1987, reversed and set aside the POEA decision and dismissed petitioner’s claim for lack of merit.

Petitioner sought certiorari, alleging the NLRC gravely abused its discretion in:

Setting aside the POEA decision despite a finding that petitioner was dismissed without due process of law, and despite the alleged disregard of jurisprudence that due process is not a mere formality.
Reversing the POEA decision purportedly without direct evidence tying petitioner to any alleged alteration of Odon Arabejo’s contract salary.
Ruling that petitioner’s claim for illegal dismissal was negated by the Release Certificate dated April 7, 1985, despite jurisprudence that quitclaims/releases signed by employees are null and void.

The Court found the ground claimed for dismissal was the alleged unauthorized alteration of Odon Arabejo’s employment contract, from a monthly base salary of $1,600.00 increased to $1,800.00, allegedly showing petitioner’s unworthiness from continuing in service.
The Release Certificate referenced was executed by the private respondent on April 7, 1983 upon receipt of petitioner’s salary, purportedly discharging the private respondent from any other claim or action.

Whether there was lawful cause for dismissal based on the alleged unauthorized alteration of Odon Arabejo’s contract salary.
Whether any direct evidence existed to show petitioner’s participation in such alleged alteration.

Whether the Release Certificate/quitclaim could negate petitioner’s claim for ...(Subscriber-Only)