G.R. No. L-2096 - People vs. Tan

Susan Sumatre, the private respondent, left for overseas employment as a domestic helper with high hopes for a better future.
Sigma Personnel Services, the petitioner, is a duly licensed recruitment agency authorized by the Philippine Overseas Employment Administration (POEA) to recruit and deploy workers for land-based overseas employment.
Marife Carandang, Vice President and Executive Officer of SPM Integrated Services, recruited Sumatre but processed her application through Sigma.

Sumatre paid a placement fee of P11,500.00 to Carandang.
A travel exit pass was issued with Sigma as the stated recruiting agency.
On August 1, 1987, Sumatre was deployed to Abu Dhabi, United Arab Emirates, to work with the National Center for Commercial Relations and Services (NCCRS).
Upon arrival in Abu Dhabi, she was met by Querisi-al-Harira, the owner of NCCRS, who assigned her to a foreign employer.

The foreign employer allegedly mauled, beat, and possibly raped Sumatre.
Following the assault, Sumatre was locked in a room for several days without food by Harira.
Two weeks after her departure to Abu Dhabi, Sumatre was repatriated to the Philippines, with the medical justification citing a schizophreniform disorder.
Medical and psychiatric examinations upon her return (including findings at Camp Crame and the National Center for Mental Health) confirmed physical injuries and a psychiatric condition, while also noting no history of previous psychiatric confinement before her departure.

On March 9, 1988, Cynthia Sumatre, the sister of Susan Sumatre, filed a complaint with the POEA for the payment of unpaid salaries amounting to US$150/month for the duration of what was argued to be a two-year contract.
Sigma contended that Sumatre had been dismissed because she failed to pass her probationary period and that her repatriation was due to her mental unsoundness, thereby alleging that the dismissal was justified.
The POEA ruled in favor of the complainant, ordering both Sigma and SPM Services to solidarily pay back wages (US$4,800.00 or its peso equivalent) and additional attorney’s fees amounting to 5% of the total award.
The NLRC affirmed the POEA decision on appeal.

Article 281 of the Labor Code permits termination of an employee on probation if the employee fails to qualify as a regular employee under the reasonable standards communicated by the employer.
Article 284 of the Labor Code provides for termination on account of a disease if the continued employment is prejudicial to the employee’s or co-employees’ health, accompanied by appropriate separation pay.
The case also involves the application of Section 2(e), Rule V, Book I, and Section 10(a)(2) of the Omnibus Rules implementing the Labor Code, which imposes joint and several liability on private employment agencies.
The statutory provisions under Section 1(f)(3) of Rule II, Book II of the POEA Rules and Regulations reinforce the recruitment agencies’ joint liability with the foreign employer in cases of violations of the recruitment agreement or employment contract.

Was Sumatre illegally dismissed despite the petitioner’s claim that she was a probationary employee and dismissed due to mental unsoundness?
Does the alleged schizophrenia justify termination under Article 284 of the Labor Code?

Did Sigma discharge its burden of proving that the dismissal was justified by the employee’s behavior and mental condition?
Was there adequate and conclusive evidence to support the claim that the injuries were self-inflicted as a result of her alleged schizophrenic condition?

Can Sigma be held solidarily liable for the unpaid salaries due to the failure in discharging its responsibilities under the recruitment agreement?
Does the regulatory framework impose joint liability on Sigma with the foreign-based employer for Sumatre’s claims?

Does Cynthia Sumatre, filing on behalf of her sister, have the capacity to sue under the rules governing labor cases and representation?