Case Summary (G.R. No. 104776)
Recruitment, Employment Contracts and Claims
From 1975 to 1983, claimants signed standard overseas-employment contracts with AIBC for deployment under BRII to Middle East and Southeast Asian projects. Contracts provided base pay, overtime rates, vacation benefits, and contained a clause adopting host-country laws if more favorable. Claimants sought unpaid wages (unexpired contract portion), overtime, leave benefits, social contributions, taxes, interest, damages, attorney’s fees, and license sanctions.
POEA and NLRC Proceedings
The POEA Administrator held hearings intermittently amid multiple motions to strike complaints, bills of particulars, and two competing counsel’s appearances. Four consolidated POEA cases (L-84-06-555; L-85-10-777; L-85-10-779; L-86-05-460) resulted in a January 30, 1989 decision awarding 324 complainants US $824,652.44. Both sides appealed to NLRC, which on September 2, 1991:
- Applied a 3-year prescription under Labor Code Art. 291;
- Recognized Bahraini Amiri Decree No. 23 only for those who worked in Bahrain, declining its benefits for others;
- Modified POEA awards—dismissing many claims for lack of evidence or competence, sustaining 149 awards, and remanding 683 dismissed claims for further hearings under Art. 218(c) of the Labor Code;
- Denied default of private respondents despite late answers and held AIBC and BRII jointly liable.
Prescription of Claims
Issue: Whether Philippine or Bahraini prescriptive periods apply and whether it is 1, 3 or 10 years. The Supreme Court held:
- Philippine “borrowing” rule (C.P.C. § 48) cannot enforce Bahrain’s 1-year bar because it conflicts with Philippine public policy protecting labor under the 1987 Constitution.
- Philippine Labor Code Art. 291’s 3-year prescription for “money claims arising from employer-employee relations” applies, overruling the POEA’s 10-year Civil Code Art. 1144 application.
Right to Speedy Disposition and Default
Claimants’ delay complaint: From June 1984 filing to January 1989 POEA decision. Under Sec. 16, Art. III of 1987 Constitution, “speedy disposition” is flexible and tested by length, reasons, assertion of right, and prejudice. Given voluminous claims (1,767 workers), multiple amendments, counsel disputes and appeals, delays were not arbitrary or oppressive. NLRC properly denied default despite late answers and extensions granted for complex, numerous pleadings.
Class-Suit Treatment Rejected
Petitioners urged class-action status under R.R. Court Rule 3 due to “similar money claims.” NLRC and Court found no common interest: not all claimants worked in Bahrain, terms varied by location, and individual claims were distinct. Class suit exception to joinder was inapplicable.
Incorporation of Bahraini Labor Law
NLRC and Supreme Court recognized that contract ambiguity must be construed against the drafter (AIBC/BRII). Contracts provided that host-country laws supply non-waivable benefits. The favorable provisions of Amiri Decree No. 23 (wages for overtime, rest days, annual leave, indemnity on termination) were deemed incorporated into the parties’ agreements for those who served in Bahrain.
Due Process and Admission of Evidence
Although NLRC criticized POEA for admitting evidence post-submission without respondent input, NLRC exercise
...continue readingCase Syllabus (G.R. No. 104776)
Procedural History
- Three Rule 65 petitions (G.R. Nos. 104776; 104911–14; 105029–32) assailing NLRC resolutions of September 2, 1991 and March 24, 1992.
- Originated in POEA Cases Nos. L-84-06-555; L-85-10-777; L-85-10-779; L-86-05-460 involving 1,767 overseas contract workers.
- Multiple appeals to NLRC; consolidation by the Supreme Court between July and October 1993 under its First Division.
Parties and Claims
- Petitioners: Bienvenido M. Cadalin, Rolando M. Amul, Donato B. Evangelista, and co-claimants represented by Atty. Gerardo A. del Mundo and Atty. Florante M. de Castro.
- Respondents: POEA Administrator; National Labor Relations Commission; Brown & Root International, Inc.; Asia International Builders Corporation.
- Reliefs sought: declaration of respondents in default; class-suit status; payment of unpaid wages/benefits (overtime, leave, unexpired contract portions, fund interests, SSS/BIR refunds, penalties, attorney’s fees); suspension of AIBC/BRII licenses; dismissal of multiplicity of suits.
Facts
- From 1975–1983, AIBC recruited Filipino workers; BRII employed them on Middle East (Bahrain, Saudi Arabia, UAE, Libya) and Southeast Asia (Indonesia, Malaysia) projects.
- Standard employment contracts fixed basic and overtime rates, leave, bonuses, off-day pay; incorporated host-country “custom” if more favorable.
- Bahrain’s Amiri Decree No. 23 (1976) guaranteed higher premiums for overtime, holiday work, annual/sick leave, indemnities, notice compensation.
- Protracted POEA proceedings: motions to strike, bills of particulars, summary-judgment motions; appeals and cross-petitions to NLRC and the Supreme Court; ombudsman complaints.
Legal Issues
- Whether and how Bahrain’s labor law (Amiri Decree No. 23) forms part of the employment contracts.
- Applicable prescriptive period: Philippine Civil Code (10 years), Labor Code (3 years), or Bahrain law (1 year