Case Summary (G.R. No. 249843)
Antecedents
Alma Tacda Manuel was deployed by Ascent to work as a domestic helper in the Kingdom of Saudi Arabia (KSA) under a two-year contract with a monthly salary of US$400.00. Shortly after deployment, Manuel raised concerns about her working conditions and refused to continue under those circumstances. She was temporarily moved to the Silver Contract Manpower Office, where she declined an offer to work in Abha, insisting on a position in Riyadh. After a period of waiting for reassignment, she requested repatriation and executed a letter of intent to return home, expressing her disinterest in continuing her contract. Upon her return to the Philippines, she filed multiple complaints against Ascent and its officers, initially for constructive dismissal before later amending her claims to include sexual harassment and trafficking.
Legal Proceedings
The case progressed through a series of legal adjudications, starting with a Labor Arbiter's initial judgment in December 2017, which found in favor of Manuel, declaring her constructive dismissal and awarding her back wages along with moral and exemplary damages. The NLRC later reversed this decision, arguing that there was insufficient evidence to support claims of constructive dismissal, asserting that Manuel had voluntarily resigned. Following this, the Court of Appeals reinstated the Labor Arbiter's ruling, leading to the current proceedings before the Supreme Court.
Issue Presented
The primary legal question concerns whether the Court of Appeals erred in reversing the NLRC's decision, which found that Alma Tacda Manuel had voluntarily resigned rather than being constructively dismissed.
Ruling of the Court
The Supreme Court affirmed the Court of Appeals’ ruling, asserting that the totality of circumstances presented indicated that Manuel suffered constructive dismissal. The Court acknowledged that while the NLRC's interpretation of events suggested that the Respondent had resigned voluntarily, the compelling nature of her allegations—including the intolerable working conditions and the harassment she experienced—supported the claim of constructive dismissal. The Court emphasized the need for a sensitive appraisal of the evidence regarding the employee's situation, noting that the burden of proving voluntary resignation lies with the employer.
Employment Contract Violations
Further, the Court highlighted specific breaches regarding the employment contract, such as the unlawful transfer from Riyadh to Abha without consent. The ruling stated that such a breach exacerbated the circumstances surrounding Manuel's repatriation and contributed to the determination of constructive dismissal.
Damages Awarded
Moral and exemplary damages awarded to Manuel were increased significantly from PHP 10,000 each to PHP 100,000 each to reflect the severity of the distress caused by the circumstances surrounding her employment and subsequent treatment. This adjustment was grounded in a need to ensure that awards in labor cases serve to protect the dignity and rights of workers, particularly in cases involving harassment and unjust treatment.
Responsibility of Petitioners
The Cour
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Case Background
- The case involves a petition filed under Rule 45 of the Rules of Court by petitioners Ascent Skills Human Resources Services, Inc. and its directors against respondent Alma Tacda Manuel.
- The petition seeks to reverse the decision of the Court of Appeals (CA) which had overturned the ruling of the National Labor Relations Commission (NLRC) in favor of the respondent.
Deployment and Initial Complaints
- On April 13, 2017, respondent was deployed to Saudi Arabia as a domestic helper for a two-year contract with a monthly salary of US$400.00.
- Just twelve days into her employment, respondent raised complaints about her working conditions and subsequently refused to work.
- Respondent was taken back to Silver Contract Manpower Office, where she remained while they sought a new employer for her.
Job Offer and Repatriation
- Silver Contract eventually offered her a position in Abha, which she declined, insisting on a job in Riyadh.
- After some time, she was taken by a former employee of Silver Contract to United Project Company (UPC), where she stayed with others awaiting repatriation.
- Respondent eventually requested repatriation and signed a letter indicating her desire to return to the Philippines without any claims against her agency.
Filing of the Complaint
- Upon returning to the Philippines, respondent filed a complaint in August 2017 against Ascent and its officers for constructive dismissal, unexpired contract wages, damages, and attorney's fees.
- The complaint was later amended to include claims for sexual harassment, discrimination, maltreatment, and trafficking.
Allegations of Abuse
- Respondent all