Case Digest (G.R. No. 74412)
Facts:
Skillworld Management and Marketing Corporation, Shary Limousine, Serafin Ramos and Alicia Ramos v. National Labor Relations Commission and Francisco R. Manuel, G.R. No. 74412, June 13, 1990, Supreme Court First Division, Medialdea, J., writing for the Court.On June 24, 1983, respondent Francisco R. Manuel was deployed by recruitment agency Skillworld Management and Marketing Corporation (operated by petitioners-spouses Serafin and Alicia Ramos) to Saudi Arabia to work as a driver for Shary Limousine; he signed a two-year employment contract providing a US$300 monthly basic salary. On August 24, 1983, Manuel was repatriated to the Philippines after being removed from his post in Saudi Arabia. Upon return, petitioners promised redeployment to other projects but more than a year elapsed without such deployment.
On January 5, 1985, Manuel filed a complaint for illegal dismissal with the Philippine Overseas Employment Administration (POEA) alleging that Saudi police twice discovered that documents his employer had represented as a temporary driver’s license were invalid, that he and other drivers brought the matter to their superiors and the Philippine Embassy, and that three days later he was ordered to pack up and was repatriated. Petitioners answered asserting that Manuel’s dismissal was for valid causes—disobedience, absenteeism, refusal to work, and concerted activity—and submitted affidavits of Shary Limousine personnel in support.
On August 21, 1985, the POEA rendered judgment for Manuel ordering payment of US$6,900 (equivalent of 23 months’ salary). Petitioners’ motion for reconsideration was treated as an appeal to the National Labor Relations Commission (NLRC), which dismissed the appeal and affirmed the POEA decision on April 28, 1986. A writ of execution issued May 30, 1986; petitioners opposed it and filed with the POEA (June 4, 1986) a Petition for Relief from Judgment raising for the first time the defense that, under Saudi law and practice, a certificate of employment together with a foreign driver’s license sufficed to drive for three months; the POEA denied relief on June 18, 1986 for lack of merit.
Petitioners sought relief from this Court by filing a petition for certiorari under Rule 65 on June 28, 1986 (after motions for extension of time), alleging grave abuse of discretion by the NLRC in affirming POEA and by the POEA in denying their petition for relief from judgment. On July 3, 1986, the Supreme Court issued a tempor...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion in affirming the POEA decision ordering payment to Manuel?
- Did the POEA commit abuse of discretion in denying petitioners’ Petition for Relief from Judgment based on a newly raised defense that Saudi law allowed foreign drivers to use foreign licenses with a certificate of employment?
- Was Manuel’s dismissal lawful because he was a probationary employee...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)