Case Digest (G.R. No. 88683)
Facts:
Rapid Manpower Consultants, Inc., petitioner, filed G.R. No. 88683; the case was decided October 18, 1990 by the Supreme Court First Division, Medialdea, J., writing for the Court. The respondents are the National Labor Relations Commission (NLRC) and the workers David Prodigalidad, Fernando Dabu, Wilfredo Nazareno and Dante San Miguel.The workers were hired by petitioner on behalf of its accredited principal, Albert Abela Group/Saudi Catering and Contracting Services, and deployed as janitors at Khaled International Airport in Riyadh, Saudi Arabia under three‑year contracts. Before the contracts expired the workers were repatriated to the Philippines allegedly for violations of company rules and Saudi law. On September 18, 1985 the workers filed with the Philippine Overseas Employment Administration (POEA) a complaint for illegal dismissal and claims for unpaid overtime, salary differential and attorney’s fees.
On January 15, 1987 the POEA rendered a decision awarding various sums for unexpired salaries, unpaid overtime and salary differential and granted ten percent attorney’s fees; it dismissed some unpaid salary claims for lack of evidence and dismissed the complaint against Ambraque International Placement & Services. Petitioner manifested on November 3, 1986 that it reserved the right to present additional evidence once obtained from its principal in Saudi Arabia, and on June 16, 1987 filed a Supplemental Memorandum on Appeal with a Motion for New Trial, claiming newly obtained documentary evidence from the employer in Saudi Arabia that would justify the dismissals.
Petitioner appealed to the NLRC on February 9, 1987 with a single assignment of error (that the POEA erred in appreciating the facts). On November 22, 1988 the NLRC affirmed the POEA decision but modified it by remanding the case for further reception of evidence only on the issue of illegal dismissal, and ordered execution on the award of overtime pay, salary differential and attorney’s fees. Petitioner sought relief from the Supreme Court by a petition for review on certiorari treated as a special civil action f...(Subscriber-Only)
Issues:
- Did the NLRC commit error by remanding only the issue of illegal dismissal and allowing execution on the monetary awards despite petitioner’s claim that it lacked reasonable time to obtain and present documentary evidence from its foreign principal?
- Was petitioner denied due process because it was not afforded a reasonable opportunity to secure and submit the additional evidence it had manif...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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