Case Summary (G.R. No. 203882)
Factual Background
La Suerte International Manpower Agency, Inc. (La Suerte), a duly authorized recruitment agency by the Philippine Overseas Employment Administration (POEA), hired Lorelei O. Iladan on March 20, 2009, to work as a domestic helper in Hong Kong for a two-year term with a monthly salary of HK$3,580. Iladan began her employment on July 20, 2009, and by July 28, 2009, she submitted a handwritten resignation letter. Subsequently, on August 6, 2009, Iladan accepted a financial assistance amounting to P35,000 from her employer, Domestic Services International, and signed an Affidavit of Release, Waiver and Quitclaim along with an agreement acknowledging that the financial assistance would serve as a final settlement of her claims against the respondents. Iladan returned to the Philippines on August 10, 2009, and later filed a complaint for illegal dismissal, seeking various monetary claims.
Claims of the Parties
Iladan alleged that she was coerced into resigning and was threatened with incarceration. She claimed ignorance of the implications of the Affidavit and the Agreement and asserted that these documents were contracts of adhesion issued for unreasonable consideration. In contrast, the respondents maintained that Iladan voluntarily resigned, relying on her resignation letter and the signed Affidavit as evidence. They denied receiving any placement fee, emphasizing the prohibition against charging such fees for domestic helpers deployed to Hong Kong under POEA regulations.
Labor Arbiter's Decision
On August 11, 2010, the Labor Arbiter ruled in favor of Iladan, declaring her dismissal illegal. The Labor Arbiter found it implausible that Iladan had voluntarily resigned given the short duration of her employment and the lack of credible justification for her resignation. The Labor Arbiter deemed the Affidavit and Agreement invalid due to the absence of legal guidance during their execution and ordered the respondents to pay Iladan various compensations, including the salary for the unexpired contract period, refund of her placement fee, and damages.
National Labor Relations Commission (NLRC) Ruling
Upon appeal by the respondents, the NLRC upheld the Labor Arbiter's ruling in a resolution dated February 23, 2011, asserting that Iladan's claims of harassment warranted credence and that the evidence did not substantiate the respondents' assertions of a voluntary resignation. However, the NLRC's decision was contested by the respondents, prompting them to file a Petition for Certiorari with the Court of Appeals.
Court of Appeals (CA) Decision
In its May 16, 2012 decision, the Court of Appeals reversed the NLRC's findings, concluding that Iladan had voluntarily resigned. The CA emphasized the validity of the signed documents and the lack of evidence supporting claims of coercion. It attributed grave abuse of discretion to the NLRC for failing to assess the evidentiary value of Iladan’s written resignations and the agreements signed before Consular officials. The CA also ruled that Iladan did not prove payment of any placement fee.
Issues Raised in the Petition
The key issues arising from Iladan's petition included whether the CA erred in reversing factual findings of the Labor Arbiter and NLRC; whether Iladan's resignation was voluntary; whether her acceptance of financial assistance constituted a final settlement of her claims; whether she was illegally dismis
...continue readingCase Syllabus (G.R. No. 203882)
Case Overview
- Court: Supreme Court of the Philippines
- Decision Date: January 11, 2016
- G.R. No.: 203882
- Petitioner: Lorelei O. Iladan
- Respondents: La Suerte International Manpower Agency, Inc. and Debbie Lao
Background of the Case
- Lorelei O. Iladan was hired by La Suerte, a recruitment agency, as a domestic helper in Hong Kong with a two-year contract and a monthly salary of HK$3,580.00.
- She was deployed to her employer, Domestic Services International, on July 20, 2009.
- Eight days into her employment, on July 28, 2009, Iladan submitted a handwritten resignation letter.
- On August 6, 2009, she accepted P35,000.00 as financial assistance from her employer and signed an Affidavit of Release, Waiver and Quitclaim, alongside an Agreement that acknowledged the financial assistance as a final settlement of her claims against the respondents.
Procedural History
- Upon returning to the Philippines, Iladan filed a complaint for illegal dismissal, seeking back wages, refund of placement fees, and damages on November 23, 2009.
- Respondents argued that Iladan voluntarily resigned and denied collecting placement fees, citing POEA regulations prohibiting such charges for domestic helpers in Hong Kong.
Rulings of the Labor Arbiter
- On August 11, 2010, the Labor Arbiter ruled in favor of Iladan, declaring her dismissal illegal and awarding her various monetary claims, including the refund of her placement fee.
Ruling of the National Labor Relations Commission (NLRC)
- The NLRC a