Case Digest (G.R. No. 78085)
Facts:
Royal Crown Internationale, petitioner, vs. National Labor Relations Commission and Virgilio P. Nacionales, respondents, G.R. No. 78085, October 16, 1989, Supreme Court Third Division, Cortes, J., writing for the Court.In 1983 Royal Crown Internationale (petitioner), a duly licensed private employment agency, recruited and deployed Virgilio P. Nacionales (private respondent) to work for Zamel‑Turbag Engineering and Architectural Consultant (ZAMEL) in Saudi Arabia as an architectural draftsman. A service agreement dated May 25, 1983 provided for US$500 monthly salary plus US$100 allowance for one year; Nacionales departed the Philippines on June 28, 1983.
On February 13, 1984 ZAMEL allegedly terminated Nacionales for poor performance. He was detained for three days, prevented from reporting to work, and on February 16, 1984 was sent back to the Philippines. Nacionales filed a complaint for illegal termination with the Philippine Overseas Employment Administration (POEA) on April 23, 1984 (POEA Case No. (L) 84‑04‑401).
The POEA Workers Assistance and Adjudication Office, in a decision dated June 23, 1986, found petitioner and ZAMEL failed to prove just cause and ordered them jointly and severally to pay specified sums for unexpired salary, vacation pay, reimbursement of salary deductions for return travel fund, and attorney’s fees; claims for legal and transportation expenses were dismissed. Petitioner moved for reconsideration on July 18, 1986; the POEA treated the filing as an appeal to the National Labor Relations Commission (NLRC).
The NLRC, in a resolution promulgated December 11, 1986, affirmed the POEA decision and held petitioner jointly and severally liable with ZAMEL for claims arising from the employment contract; its March 30, 1987 resolution denied petitioner’s motion for reconsideration. Petitioner filed a "Petition for Review" to the Supreme Court under Rule 45; the Court, noting Rule 45 was not the proper vehicle for NLRC decisions, opted to treat the petition as one for certiorari under Rule 65 in the interest of justice and considered the case on the merits.
The Court framed two issues: (1) whether a private employment agency may be held jointly and severally liable wit...(Subscriber-Only)
Issues:
- May a private employment agency be held jointly and severally liable with a foreign‑based employer for claims arising from implementation of the employment contracts of workers it recruited and deployed abroad?
- Did petitioner present sufficient evidence to prove that private respondent’s employment was terminated ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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