Facts:

The case involves petitioners Ramon Rase and Rosita Rase, who are the parents of Marilyn Rase, an overseas contract worker. The respondents are the National Labor Relations Commission (NLRC), G & M (Phils.), Inc., and Riyadh Medical Center. The events leading to the case began when Marilyn was recruited by G & M and subsequently deployed to Riyadh Medical Center in Saudi Arabia on July 2, 1987, to work as a nursing aide with a monthly salary of US$400.00. However, shortly after her arrival, Marilyn was made to work as a domestic helper for Sheik Fahad Al Owaidah, which was a violation of her employment contract. On March 6, 1989, Marilyn died from acute viral encephalitis while working in this capacity. Following her death, on March 20, 1989, her parents filed a complaint with the Philippine Overseas Employment Administration (POEA) seeking recovery of salary differentials, death and burial benefits, and reimbursement for the expenses incurred in recovering Marilyn...

Facts:

1. Recruitment and Deployment: Marilyn Rase, an overseas contract worker, was recruited by G & M (Phils.), Inc. and deployed to Riyadh Medical Center in Saudi Arabia as a nursing aide with a monthly salary of US$400.00.
2. Change of Employment: A few days after her arrival in Saudi Arabia, Marilyn was made to work as a domestic helper for Sheik Fahad Al Owaidah, contrary to her approved contract.
3. Death: Marilyn died on 6 March 1989 due to acute viral encephalitis while working as a domestic helper.
4. Complaint Filed: Marilyn’s parents, Ramon and Rosita Rase, filed a complaint before the Philippine Overseas Employment Administration (POEA) seeking salary differential, death and burial benefits, and reimbursement of P50,000.00 spent for her remains and burial.
5. Evidence Presented:
   • Marilyn’s letter dated 24 July 1987, stating she was working as a domestic helper with a salary of SR150.00.
   • Affidavit of Imelda Enciong, a co-worker, confirming Marilyn’s employment as a domestic helper with a salary of SR150.00 for the first six months and SR350.00 thereafter.
6. Defense of G & M: G & M denied knowledge of Marilyn’s change of employment and claimed she voluntarily resigned from Riyadh Medical Center, as evidenced by a letter dated 18 August 1987 accepting her resignation.
7. POEA Decision: The POEA ruled in favor of the petitioners, awarding salary differential, death benefits, and burial allowance.
8. NLRC Decision: The National Labor Relations Commission (NLRC) reversed the POEA decision, ruling that Marilyn voluntarily resigned and was not entitled to the claimed benefits.

Issue:

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Ruling:

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Ratio:

1. Substantial Evidence in Administrative Proceedings: The POEA’s decision was based on substantial evidence, which is sufficient in administrative proceedings. The NLRC erred in requiring stricter evidence and disregarding the POEA’s findings.
2. Presumption of Regularity: Marilyn’s compliance with her employment contract and the presumption that she took ordinary care of her concerns were upheld. The Court found it unlikely that Marilyn voluntarily resigned from a higher-paying job to work as a domestic helper for a lower salary.
3. Burden of Proof on Employer: In claims for underpayment, the burden of proof lies on the employer to show that the worker was fully paid. G & M failed to provide sufficient evidence to counter the petitioners’ claim.
4. Work-Connected Death: The Court ruled that there was insufficient evidence to prove that Marilyn’s death was work-connected. Acute viral encephalitis can be caused by various factors, and no evidence linked her illness to her work environment.
5. Protection of Overseas Workers: The Court emphasized the need to protect overseas workers from exploitation and abuse, especially in foreign countries where they lack legal support and are vulnerable to violations of their rights.