G.R. No. 230018 - Lazaro vs. People

Respondents, comprising Armando A. Vinuya, Louie M. Ordovez, Arsenio S. Lumanta, Jr., Robelito S. Anipan, Virgilio R. Alcantara, Marino M. Era, Sandy O. Enjambre, and Noel T. Ladea, filed a complaint for illegal dismissal against petitioner Pert/CPM Manpower Exponent Co., Inc. and its president, Romeo P. Nacino.
The respondents were deployed between March 29, 2007 and May 12, 2007 to work in Dubai as aluminum fabricators/installers under a POEA‑approved two‑year employment contract with Modern Metal Solution LLC.

The original contract provided for a monthly salary of 1,350 AED, fixed working hours, overtime pay, free food allowance, housing, transportation, laundry, and medical/dental services—with the respondents each paying a processing fee.
On April 2, 2007, Modern Metal issued appointment letters with altered terms, extending the employment to three years and reducing the salary range to 1,000–1,200 AED and the food allowance to 200 AED.
On May 5, 2007, the respondents were compelled to sign new employment contracts mirroring the appointment letters, effectively substituting the POEA‑approved contracts.

The respondents complained of oppressive working conditions: excessively long work days (from 6:30 a.m. to 6:30 p.m. with limited breaks), underpaid or unpaid overtime, and drastic reduction in benefits.
Housing conditions were far from adequate; the respondents were housed in overcrowded accommodations shared with up to 27 other workers in Sharjah—far removed from the worksite—resulting in minimal sleep and compromised living conditions.

Frustrated by the substandard conditions and the agency’s inaction, the respondents expressed their desire to resign. While most cited “personal/family problems” (allegedly out of fear of non-payment and non-release of documents), one respondent disclosed that the real reason was to protest company policy.
The respondents were eventually repatriated to the Philippines, with some bearing their own airfare expenses.
The agency contended that the respondents voluntarily resigned to pursue better-paying jobs and even pointed to the signing of affidavits of quitclaim and release as evidence of a voluntary termination.

Labor Arbiter Decision: On April 30, 2008, Labor Arbiter Ligerio V. Ancheta dismissed the complaint on the ground that the respondents had resigned voluntarily, also noting that some had executed compromise agreements (with quitclaim and release) before the POEA.
NLRC Ruling: On May 12, 2009, the NLRC reversed the Labor Arbiter’s decision, holding that the respondents were illegally dismissed based on the contract substitution and compounding neglect by the agency. The NLRC ordered payment of salaries for the unexpired portion of the contracts along with other monetary benefits and attorney’s fees.
Court of Appeals (CA) Decision: The CA affirmed the NLRC ruling, rejecting the arguments that the resignation letters and compromise agreements evidenced voluntary resignation. The CA noted that the resignation letters were dubious in that they seemingly aimed to exonerate the employer.
Petition for Certiorari: The agency sought further relief from the CA, challenging (a) the finding of illegal dismissal, (b) the interpretation of the compromise agreements as covering only pre-deployment issues, and (c) the application of the Serrano ruling in computing salary benefits for the unexpired term of the contracts.

The agency argued that the respondents voluntarily resigned and that the subsequent signing of affidavits, quitclaims, and compromise agreements evidenced such resignation.
It maintained that the Serrano ruling should not be applied retroactively, especially given the filing timeline and the later enactment of R.A. 10022 which purportedly restored disputed contractual provisions.

The respondents countered that they were effectively forced to resign due to unbearable and exploitative conditions, making the resignation a matter of constructive dismissal.
They stressed that the quitclaim and compromise agreements were executed under duress and only addressed pre-deployment issues (e.g., airfare reimbursement), leaving unresolved the post-deployment claims for illegal dismissal and underpayment.

Whether the respondents’ resignations were truly voluntary or a product of constructive dismissal under oppressive and altered working conditions.

The genuineness of the family-related reasons cited versus the evidenced duress from contract substitution and poor work conditions.

Whether the substitution of the POEA‑approved employment contract with the appointment letters and new contracts was a breach of law.

The legality of altering employment terms without the approval of the Department of Labor.

The admissibility and evidentiary value of the quitclaim and release affidavits and the compromise agreements executed before the POEA.

Whether such documents, signed under conditions of duress, can bar the claims of illegal dismissal.

The appropriate computation of monetary benefits for the unexpired portion of the employment contracts.

The applicability and retroactive effect of the Serrano ruling in determining the salary benefits despite the subsequent enactment of R.A. 10022.

Procedural issues regarding forum shopping and whether the pre-deployment compromise agreements can discharge the agency’s liability for post-deployment claims.