G.R. No. 177576 - Universal Staffing Services, Inc. vs. National Labor Relations Commission

Respondent Grace M. Morales applied for a receptionist position and was hired by petitioner Universal Staffing Services, Inc. (USSI) on behalf of its principal, Jin Xiang International Labour Supply of United Arab Emirates (U.A.E.).
The employment contract, duly approved by the Philippine Overseas Employment Administration (POEA), provided for a two-year term with a monthly salary of Dhs1,100.00.
On February 2, 2002, Morales departed for Abu Dhabi, U.A.E. to work at Al Sandos Suites (Al Sandos).

After ten months of work, on December 13, 2002, Morales’ employment was terminated by her employer, allegedly due to poor performance.
Morales received Dhs1,300.00 as full and final settlement of all her claims on January 1, 2003, and was repatriated on January 7, 2003.

Morales asserted that she was illegally dismissed and filed a complaint for illegal dismissal and non-payment of overtime and vacation pay before the Labor Arbiter, which was docketed as OFW Case No. 03-04-0973-00.
In her complaint, Morales contended that her termination was illegal, challenging USSI’s assertion that the dismissal was justified by poor performance and grave misconduct (notably, the charge of leaking confidential information).
USSI defended its decision, asserting that Morales’ unsatisfactory performance and alleged misconduct justified her termination; it also raised that all procedures, including due notice and settlement through authenticated documents, had been adequately observed.

On April 2, 2004, the Labor Arbiter rendered a decision dismissing Morales’ complaint, finding no conclusive evidence that would render the dismissal illegal. Key evidence included a termination letter, certification of termination, a final settlement, and an exit clearance authenticated by the Labour Attaché of the Philippine Embassy in Dubai.
Morales appealed the Labor Arbiter’s ruling, and the National Labor Relations Commission (NLRC) reversed the previous decision by determining that no substantial evidence existed to support USSI’s claim of a justified dismissal. The NLRC ordered USSI to pay Morales Dhs3,300.00 (or its peso equivalent) for the unexpired portion of her contract.
The Court of Appeals (CA) further modified the NLRC decision by increasing the award; it ordered USSI to pay Morales salaries equivalent to six (6) months, additional overtime and holiday pay, plus ten percent (10%) of the total award as attorney’s fees.
USSI filed a motion for reconsideration with the CA, which was denied on May 3, 2007.
Subsequently, USSI filed a petition for review on certiorari with the Supreme Court, challenging the rulings of the NLRC and the CA.

Whether the reversal by the NLRC of the Labor Arbiter’s decision—declaring Morales’ termination as justified—was warranted given the evidence (or lack thereof) supporting USSI’s claim of poor performance.
Whether the alleged “poor performance” was substantiated by concrete, particular acts that would justify dismissal under the standards of gross and habitual neglect of duties.

Whether the Court of Appeals erred in modifying the NLRC decision by awarding additional benefits (i.e., six months’ salary, overtime pay, holiday pay, and attorney’s fees) beyond what Morales had been granted in the NLRC decision.
Whether a party that did not appeal the NLRC decision could subsequently receive any enhanced relief from the appellate court.