G.R. No. 123354 - Philippine Integrated Labor Assistance Corp. vs. National Labor Relations Commission

Leonora L. Dayag, a former Department of Social Welfare and Development (DSWD) social worker dissatisfied with her income, sought employment abroad.
Philippine Integrated Labor Assistance Corporation (PHILAC) acted as the petitioner and recruiter for overseas employment.

Dayag complied with all requirements for overseas employment and paid a placement fee of P22,500 on five separate occasions.
Despite the payments, PHILAC did not issue complete receipts, claiming that the payments were properly recorded in a log book.

On January 11, 1992, Dayag signed an employment contract with PHILAC for a fixed two-year term.
The contract stated her engagement as a domestic helper/babysitter in Hong Kong with a monthly salary of HK$3,200 and an allowance of HK$20 per day.
The contract included a clause (Clause 12) with twin provisions:

A requirement for one-month notice (or wages in lieu thereof) upon early termination.
A provision that allowed the employer to terminate the contract without notice or payment in lieu thereof under certain conditions.

Dayag departed for Hong Kong on May 7, 1992 and commenced work on May 8, 1992 as the domestic helper for the family of Roger Chan Chan Hongas.
On the seventh day of her employment, she was abruptly dismissed when instructed by Mr. Hongas’s wife to “pack-up” and leave immediately.
At the time of dismissal, she was given HK$750 for the services rendered up to that point.

Upon her return to the Philippines, Dayag filed a complaint for illegal dismissal, illegal exaction due to the non-issuance of receipts, and claimed payment of HK$76,000 for the unexpired portion of her contract.
PHILAC defended itself by alleging that her dismissal was for just cause, citing dishonesty and misrepresentation in her employment application (regarding her previous work as a househelper and babysitter).

The Philippine Overseas Employment Agency (POEA) found that Dayag was dismissed without just cause and ordered PHILAC to pay her HK$76,053.18 (or its peso equivalent) for the unexpired contract period.
PHILAC subsequently appealed to the National Labor Relations Commission (NLRC), but limited its appeal solely to the monetary award for the unexpired portion of the contract.
Both POEA and NLRC found in favor of Dayag, determining that the dismissal was without just cause.

PHILAC contended that its liability should be limited to a 15-day salary indemnity under Article 149 of the Labor Code, rather than payment for the unexpired portion of the contract.
They argued that the contractual provision on termination was meant to secure the payment of a penalty or damages arising from dismissal without notice.

The Supreme Court reviewed the records and found no grave abuse of discretion in the findings of the POEA and NLRC.
The Court held that the burden was on PHILAC to prove that Dayag’s dismissal was for a just or lawful cause—a burden which it failed to meet.
The Court clarified that the indemnity under Article 149 (15-day salary) is awarded in addition to the salary for the unexpired portion of the contract and cannot substitute it.
Citing settled rules on contract interpretation and the incorporation of public policy laws, the Court also held that ambiguities in a contract are interpreted against the party that drafted them (in this case, PHILAC).
Finally, as Dayag failed to appeal the monetary award, the additional 15-day salary indemnity relief was not granted.

Whether Dayag’s dismissal was justified and based on a lawful “just cause” as alleged by PHILAC.
Whether PHILAC discharged its burden to prove that the dismissal was the result of dishonesty and misrepresentation on the part of Dayag.

Whether PHILAC is liable to pay the salary corresponding to the unexpired portion of the employment contract, as ordered by the POEA and NLRC.
Whether PHILAC’s contention that its liability is limited to a 15-day salary indemnity under Article 149 is legally tenable.

Whether the contractual clause regarding termination (Clause 12) precludes the obligation to remunerate Dayag for the unexpired portion of the contract.
Whether the employment contract effectively incorporates Article 149 of the Labor Code, which provides for indemnity in cases of unjust dismissal.

Whether the findings of the quasi-judicial bodies (POEA and NLRC) are supported by substantial evidence and thus merit deference by the Supreme Court.