Case Digest (G.R. No. 169973)
Case Digest (G.R. No. 169973)
Facts:
Placewell International Services Corporation v. Ireneo B. Camote, G.R. No. 169973, June 26, 2006, First Division, Ynares‑Santiago, J., writing for the Court.On August 15, 1999, petitioner Placewell International Services Corporation (PISC) deployed respondent Ireneo B. Camote as a building carpenter to work for SAAD Trading and Contracting Co. (SAAD) in the Kingdom of Saudi Arabia under a two‑year POEA‑approved contract at a salary of US$370.00 per month. At the job site, SAAD allegedly found Camote incompetent and terminated him; Camote pleaded to be retained and purportedly accepted a lower salary of SR 800.00 per month to keep working until his contract’s two‑year term expired.
On November 27, 2001, Camote filed a sworn complaint for money claims against PISC, alleging that he and fellow Filipino workers were compelled to sign another employment contract in Arabic under threat of job loss; that he was paid only SR 590.00 per month for the duration of the new contract; that he did not receive overtime pay despite rendering nine hours of work daily; and that embassy intervention proved ineffective.
On May 31, 2002, Labor Arbiter Arturo L. Gamolo ruled in favor of Camote, finding the modification of the POEA‑approved contract void under R.A. No. 8042 (the Migrant Workers and Overseas Filipinos Act of 1995) and awarding P215,424.00 for underpayment of wages and attorney’s fees (attorney’s fees set at 10% of the award). The NLRC thereafter reviewed the case and issued a resolution vacating the labor arbiter’s decision and dismissing the case for lack of cause of action (the decision the petition now challenges).
Petitioner filed a Rule 65 certiorari petition in the Court of Appeals. The Court of Appeals, in CA‑G.R. SP No. 77145 (decision dated September 27, 2005, penned by Justice Flores), set aside the NLRC resolution, reinstated with modifications the labor arbiter’s May 31, 2002 decision, found that the diminution of salary from US$370.00 to SR 800.00 violated Section 10 of R.A. No. 8042, and ordered PISC jointly and severally liable with SAAD for unpaid money claims. The CA’s computation included an item for “Unauthorized Deductions” amounting to P171,780.00 and awarded attorney’s fees (5% in the CA computation).
PISC filed this Petition for Review on Certiorari under Rule 45 assailing the Court of Appeals’ decision. PISC argued inter alia that Camote failed to prove coercion to sign the alleged side agreement, that laches barred the claim because Camote delayed reporting problems until after repatriation, that the CA’s award for unauthorized deductions lacked basis, and that attorney’s fees were unwarranted.
Issues:
- Did the Court of Appeals correctly set aside the NLRC resolution and reinstate the labor arbiter’s decision holding that the substitution or diminution of a POEA‑approved overseas employment contract is void under R.A. No. 8042 and that the recruitment agency is jointly and severally liable?
- Is Camote’s claim barred by laches for failing to notify petitioner earlier of the alleged coercion and salary diminution?
- Was the Court of Appeals’ award for unauthorized deductions in the amount of P171,780.00 supported by factual and legal basis?
- Is Camote entitled to attorney’s fees?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)