Case Digest (G.R. No. 78085)
Facts:
The case of Royal Crown Internationale vs. National Labor Relations Commission and Virgilio P. Nacionales (G.R. No. 78085) was decided by the Supreme Court on October 16, 1989. The petitioner, Royal Crown Internationale, is a licensed private employment agency that recruited and deployed Virgilio P. Nacionales, the private respondent, as an architectural draftsman to Zamel-Turbag Engineering and Architectural Consultant (ZAMEL) in Saudi Arabia in 1983. A service agreement was signed, providing for a monthly salary of US$500.00 plus US$100.00 in allowances for a contract period of one year. On June 28, 1983, Nacionales arrived in Saudi Arabia, but on February 13, 1984, his employment was terminated by ZAMEL, citing his performance as below par. Following this, Nacionales was detained for three days and was barred from work until his exit papers were ready, and on February 16, 1984, he was sent back to the Philippines.
On April 23, 1984, Nacionales filed a complaint for illegal t
Case Digest (G.R. No. 78085)
Facts:
- Background of the Case
- Petitioner: Royal Crown Internationale, a duly licensed private employment agency for overseas recruitment and placement.
- Respondents:
- National Labor Relations Commission (NLRC)
- Virgilio P. Nacioniales, a private respondent who was recruited and deployed abroad by petitioner.
- Employment Arrangement:
- In 1983, petitioner recruited private respondent for employment with Zamel-Turbag Engineering and Architectural Consultant (ZAMEL) as an architectural draftsman in Saudi Arabia.
- A service agreement was executed on May 25, 1983, stipulating a monthly salary of US$500.00 plus US$100.00 as allowances for one year, commencing from the date of arrival in Saudi Arabia.
- Private respondent departed for Saudi Arabia on June 28, 1983.
- Termination of Employment
- On February 13, 1984, ZAMEL terminated private respondent on the ground that his performance was below par.
- For three successive days following the termination, private respondent was confined to his quarters and was not allowed to report to work, pending the processing of his exit papers.
- Subsequently, on February 16, 1984, he was sent back to the Philippines.
- Filing of Complaint and Administrative Proceedings
- Private respondent filed a complaint for illegal termination against petitioner and ZAMEL on April 23, 1984, which was docketed as POEA Case No. (L) 84-04-401.
- The POEA, via its Workers Assistance and Adjudication Office, found in favor of the respondent on June 23, 1986.
- The decision ordered joint and several payment by petitioner and ZAMEL for:
- Salary corresponding to the unexpired portion of the contract (US$2,640.00).
- Unpaid vacation pay (US$600.00 less partial payment of SR558).
- Reimbursement for salary deductions for return travel fund (US$350.00).
- Ten percent (10%) attorney’s fees on the above amounts.
- Claims for legal and transportation expenses were dismissed.
- Appeal and Motion for Reconsideration
- On July 18, 1986, petitioner filed a motion for reconsideration (treated as an appeal) contesting the POEA decision.
- Petitioner argued that it should not be held jointly and severally liable with ZAMEL because:
- It was not a party to the service agreement.
- The applicable rules did not provide for “third-party liability” of a recruitment agency.
- The NLRC, in its resolution dated December 11, 1986, affirmed the POEA decision, holding petitioner liable based on its contractual undertakings submitted to the Bureau of Employment Services.
- On March 30, 1987, the NLRC denied petitioner’s subsequent motion for reconsideration.
- Petitioner then filed the “Petition for Review” before the Supreme Court, which was treated as a petition for certiorari in the interest of justice.
Issues:
- Liability Issue
- Whether petitioner, as a private employment agency, may be held jointly and severally liable with the foreign-based employer (ZAMEL) for any claims arising from the implementation of the employment contract or service agreement.
- Justification of Termination
- Whether sufficient evidence was presented by petitioner to establish that private respondent was terminated for just and valid cause in accordance with his service agreement with ZAMEL.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)