Case Digest (G.R. No. 170139) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sameer Overseas Placement Agency, Inc. v. Joy C. Cabiles, petitioner Sameer Overseas Placement Agency, Inc., a duly licensed Philippine recruitment and placement agency, facilitated the overseas deployment of respondent Joy C. Cabiles for a one-year quality control position with Taiwan Wacoal Co. Ltd. Respondent signed her contract on June 10, 1997, at a monthly salary of NT$15,360 and allegedly remitted a placement fee of ₱70,000, although petitioner’s records showed payment of only ₱20,360. Respondent left Manila on June 26, 1997, but was assigned work as a cutter rather than in quality control. On July 14, 1997, without prior written notice or hearing, she was informed by Wacoal’s representative of her immediate termination and repatriation; she received NT$9,000 for her two-week service with NT$3,000 withheld for airfare. On October 15, 1997, respondent filed a complaint with the National Labor Relations Commission (NLRC) for illegal dismissal, reimbursement of placement Case Digest (G.R. No. 170139) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract Formation and Deployment
- Sameer Overseas Placement Agency, Inc. (petitioner) advertised quality-control positions in Taiwan; respondent Joy C. Cabiles applied.
- On June 10, 1997, respondent signed a one-year contract with Taiwan Wacoal Co. Ltd. for NT$15,360 monthly and allegedly paid petitioner a placement fee of ₱70,000.
- Termination and Withheld Wages
- On July 14, 1997, Wacoal informed respondent—without prior notice—that her services were terminated effective immediately; she was repatriated the same day.
- Wacoal paid her NT$9,000 for work performed, withholding NT$3,000 to cover her plane ticket back to Manila.
- Administrative Proceedings
- October 15, 1997: Respondent filed a complaint with the NLRC against petitioner and Wacoal for illegal dismissal, refund of placement fee, unpaid salaries, and damages.
- 1998: The Labor Arbiter dismissed the complaint for lack of proof on excess placement fee and transfer of obligations to Pacific Manpower & Management Services, Inc.
- March 31, 2004: NLRC reversed, finding illegal dismissal; awarded three months’ salary (NT$46,080), NT$3,000 reimbursement, and NT$300 attorney’s fees.
- June 27, 2005: Court of Appeals affirmed NLRC on illegal dismissal and monetary awards; remanded third-party complaint against Pacific.
- 2014: Supreme Court granted certiorari to review illegal dismissal finding, monetary awards, transfer of obligations issue, and constitutionality of R.A. 8042’s cap on money claims.
Issues:
- Whether respondent’s dismissal was illegal for lack of just cause and failure to observe procedural due process.
- Whether petitioner validly transferred its contractual obligations to Pacific Manpower & Management Services, Inc.
- Whether the phrase “or for three (3) months for every year of the unexpired term, whichever is less” in Section 10 of R.A. No. 8042 (as amended by R.A. No. 10022) is constitutional.
- What interest rate applies to the monetary awards.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)