Case Digest (G.R. No. 129584) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Triple Eight Integrated Services, Inc. v. National Labor Relations Commission, respondent Erlinda Osdana was recruited in August 1992 by petitioner to serve overseas under a 36-month Food Server contract at Gulf Catering Company (GCC) in Riyadh, Saudi Arabia, for SR550. She paid P11,950 in undocumented placement fees and underwent a medical examination by an accredited clinic, which declared her fit. Before deployment, she signed a 12-month “Contractor-Employee Agreement” as a waitress at USD280, approved by the POEA. Upon arrival on September 16, 1992, she was assigned to Oleysha University to wash dishes, clean utensils and perform janitorial tasks for 12-hour shifts without overtime pay, causing numbness and pain in her arms. She was confined at the Ladies Villa from June 18 to August 22, 1993, unpaid; thereafter, worked as food server and cook at Hota Bani Tameem Hospital from August 22 to October 5, 1993, unpaid; confined again from October 6 to October 23, 1993, unpaid; Case Digest (G.R. No. 129584) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioner: Triple Eight Integrated Services, Inc. (domestic recruitment agency).
- Private Respondent: Erlinda R. Osdana (overseas Filipino worker); Labor Arbiter Potenciano S. Canizares, Jr.; National Labor Relations Commission (NLRC).
- Relief sought: Unpaid/underpaid salaries, salary differential, salaries for unexpired contract, moral and exemplary damages, attorney’s fees.
- Recruitment and Employment Contracts
- August 1992: Osdana recruited for Gulf Catering Company (GCC) in Saudi Arabia under a 36-month “Food Server” contract at SR550; she allegedly paid P11,950 placement fees; underwent medical exam and found “Fit for Employment.”
- Subsequent “Contractor-Employee Agreement” signed, for 12 months at US$280; approved by POEA; departed September 16, 1992.
- Work Assignments and Medical Conditions
- Initial posting at Oleysha University (College of Public Administration): performed dishwashing, janitorial work, 12-hour shifts without overtime; developed arm numbness and pain; confined June 18–August 22, 1993, without pay.
- Assignment as Food Server/Cook at Hota Bani Tameem Hospital (Aug. 22–Oct. 5, 1993), seven days/week, no compensation; confined Oct. 6–23, 1993, without reason or pay; returned to menial tasks thereafter.
- Diagnosed with bilateral Carpal Tunnel Syndrome; underwent surgeries in January and April 1994; not assigned light duties despite medical fitness between operations; no pay from Feb. to Apr. 22, 1994.
- Discharged April 29, 1994 on ground of illness; no separation pay or unpaid salaries; repatriated to the Philippines; POEA complaint filed.
- Labor Arbiter and NLRC Proceedings
- Labor Arbiter decision (Aug. 20, 1996): ordered payment of US$2,499 (unexpired contract), US$1,076 (unpaid salary/differential), P50,000 moral damages, P20,000 exemplary damages, and 10% attorney’s fees.
- NLRC Decision (Mar. 11, 1997) and denial of reconsideration (Apr. 28, 1997): affirmed labor arbiter.
- Petition for certiorari before the Supreme Court alleging grave abuse of discretion.
Issues:
- Whether the labor arbiter and NLRC gravely abused discretion by not stating facts and law constituting the basis of their decisions.
- Whether Osdana was validly terminated for illness under Article 284 of the Labor Code and its rules, and if the medical-certificate requirement was satisfied.
- Whether the awards for salaries (unexpired contract, unpaid salary, salary differential) conform to RA 8042 and existing jurisprudence.
- Whether liability is joint and several with GCC, and whether petitioner can be solely held liable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)