Case Summary (G.R. No. 140495)
Factual Background
Cruz was recruited by G & M as a trailer driver with a contract stipulating a monthly salary of US$625, beginning June 6, 1990. However, upon his arrival in Saudi Arabia, Cruz claimed he was made to sign a blank contract, and his salary was subsequently reduced to SR604. He alleged that after seven months of employment, he was deported on December 28, 1990, due to complaints regarding substandard working conditions and unpaid wages. He filed a complaint for illegal dismissal and other claims against G & M for underpayment and refund of transportation costs.
Petitioner’s Position
G & M contended that Cruz abandoned his position by participating in an illegal strike and thus breached his employment contract, justifying his termination. G & M disputed the authenticity of Cruz's pay slip and claimed it was inadmissible due to lack of an original copy and insufficient proof of its genuineness.
Administrative and Appellate Findings
The Labor Arbiter largely sided with the claim of abandonment but acknowledged Cruz's entitlements for underpayment and the unpaid salary for two months. Cruz was awarded a total sum of P77,455.00 and US$1,250. G & M's partial appeal before the National Labor Relations Commission (NLRC) was dismissed, maintaining Cruz's claims while ordering both G & M and Salim Al Yami Est. to be held jointly and severally liable for the unpaid wages.
Judicial Review
G & M attempted to seek redress via a special civil action for certiorari in the Court of Appeals, which was dismissed for lack of merit. The subsequent petition for review on certiorari to the Supreme Court raised issues primarily concerning the burden of proof regarding salary payments and alleged underpayment.
Burden of Proof
The Supreme Court reiterated that the burden of proof regarding wage payments lies with the employer. Even when a claimant admits to receiving partial payments, it does not absolve the employer of the responsibility to demonstrate that the employee was fully compensated in accordance with the employment agreement. Cruz's admission of receiving SR604 did not negate G & M's obligation to validate that the total payments met the stipulated pay of US$625.
Admissibility of Evidence
The Court also addressed the admissibility of Cruz's pay slips, which the NLRC deemed valid evidence. The Supreme Court confirmed that proceedings before the NLR
...continue readingCase Syllabus (G.R. No. 140495)
Case Summary
- The case revolves around a petition filed by G & M (Phils.), Inc. against Epifanio Cruz concerning issues of illegal dismissal, underpayment, and non-payment of wages.
- The Supreme Court's decision emphasizes the significance of findings by quasi-judicial bodies, particularly the National Labor Relations Commission (NLRC), and the respect these findings command when supported by substantial evidence.
Background of the Case
- G & M (Phils.), Inc. recruited Cruz as a trailer driver for its foreign principal, Salim Al Yami Est., for a term of two years at a salary of US$625 monthly starting June 6, 1990.
- Upon arrival in Saudi Arabia, Cruz was asked to sign a blank employment contract, and his salary was reportedly reduced to SR604.00.
- Cruz was deported seven months later on December 28, 1990, allegedly due to his complaints regarding working conditions, non-payment of wages, and changes in employer.
Claims and Allegations
- Cruz filed a complaint against G & M (Phils.), Inc. citing illegal dismissal, underpayment, and non-payment of wages, claiming he was only compensated for five months of salary and not paid for the last two months.
- He submitted a pay slip demonstrating his reduced salary of SR604.00.
Petitioner’s Defense
- G & M (Phils.), Inc. argued that Cruz abandoned his job by participating in an i