Title
Universal Staffing Services, Inc. vs. National Labor Relations Commission
Case
G.R. No. 177576
Decision Date
Jul 21, 2008
Grace Morales, a receptionist in the UAE, was terminated for alleged poor performance. Courts ruled her dismissal illegal due to lack of evidence and due process, awarding her three months' salary but denying additional claims.
A

Case Digest (G.R. No. 177576)

Facts:

Respondent Grace M. Morales applied for and was hired as a receptionist by petitioner Universal Staffing Services, Inc. (USSI) in behalf of its principal, Jin Xiang International Labour Supply of the United Arab Emirates (U.A.E.). The duly approved contract by the Philippine Overseas Employment Administration (POEA) provided for an employment term of two (2) years with a monthly salary of Dhs1,100.00. On February 2, 2002, Morales left for Abu Dhabi, U.A.E., and upon arrival worked as receptionist at Al Sandos Suites (Al Sandos). After ten (10) months, or on December 13, 2002, her employment was terminated allegedly due to her poor work performance. Morales received Dhs1,300.00 as full and final settlement of all claims on January 1, 2003, and was repatriated on January 7, 2003. Morales then filed a complaint before the Labor Arbiter for illegal dismissal and non-payment of overtime and vacation pay against USSI and Al Sandos, docketed as OFW Case No. 03-04-0973-00. USSI traversed the complaint and insisted that Morales was dismissed for just cause and with due process, asserting that her performance as receptionist was unsatisfactory and that, despite chances given, it did not improve, prompting Al Sandos to pre-terminate her employment contract upon payment of benefits due. On April 2, 2004, the Labor Arbiter dismissed Morales’ complaint, crediting USSI’s position that Morales was informed of charges, that the documentary acts were authenticated and noted by the Labor Attache, and that the final settlement and quitclaim should be given weight absent proof of threat or intimidation. On appeal, the NLRC reversed the Labor Arbiter and found no substantial evidence for a valid dismissal, ordering USSI to pay Morales the peso equivalent of Dhs3,300.00 representing salaries for the unexpired portion of her contract pursuant to Section 10 of R.A. No. 8042, while affirming the denial of overtime pay and holiday pay for lack of basis. Only USSI elevated the case to the Court of Appeals via certiorari. On February 12, 2007, the CA sustained the NLRC’s finding of unlawful termination but modified the awards by increasing them, ordering salaries equivalent to six (6) months, overtime pay and holiday pay, and ten percent (10%) attorney’s fees, and remanding the records for computation. The CA denied USSI’s motion for reconsideration on May 3, 2007, leading USSI to file a petition for review on certiorari under Rule 45.

Issues:

Whether the Court of Appeals committed reversible error in affirming the finding of illegal dismissal and in modifying the monetary awards in a manner that exceeded what Morales had received under the NLRC decision, considering that Morales did not appeal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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