Case Summary (G.R. No. 90394-97)
Background of the Case
The petitioners sought overseas employment through CBT/Shiek International, an unlicensed recruitment agency. They engaged the services of the Ngohos, paid placement fees, and later received assistance from Espeno, who processed their paperwork. Upon arrival in Doha, the petitioners worked for four months without receiving any salaries. Following their return to the Philippines, they filed a complaint against All Seasons Manpower International Services for unpaid wages and sought recovery for their placement fees.
Initial Rulings
The Philippine Overseas Employment Administration (POEA) initially ruled in favor of the petitioners, ordering the refund of placement fees, but dismissing the claims for unpaid salaries due to lack of merit. Both parties appealed the decision, resulting in the NLRC subsequently awarding the petitioners four months of unpaid salaries but later retracting this decision to dismiss the case entirely after a motion for reconsideration from the private respondent.
Legal Issues and Arguments
The core issue addressed was whether a recruitment agency can be held liable for unpaid wages and claims when the recruitment was conducted without its knowledge or consent. The petitioners argued that public respondent committed a grave abuse of discretion in dismissing their case. However, the court indicated that it does not act as a trier of fact and respects the findings of administrative bodies like the NLRC unless a grave abuse of discretion is shown.
Findings of the Court
The court concluded that the petitioners failed to demonstrate that All Seasons Manpower International Services could be held liable. Key findings included that the petitioners directly applied to an unlicensed recruitment agency (CBT/Shiek International) and that their employment was contracted under this agency rather than the licensed entity. Importantly, the court noted that the documents used by the petitioners for deployment were deemed fake, and both the petitioners and Espeno ut
...continue readingCase Syllabus (G.R. No. 90394-97)
Case Background
- This case revolves around the liability of a recruitment agency for unpaid wages and other claims made by overseas workers allegedly recruited by the agency's unlicensed agent.
- Petitioners applied for overseas employment in Doha, Qatar, through CBT/Shiek International, an unlicensed recruitment agency managed by Francisco and Corazon Ngoho.
- The petitioners were assisted by Erlinda Espeno, a liaison officer of All Seasons Manpower International Services, a licensed placement agency, to complete their travel processes.
- Petitioners paid their placement fees to the Ngohos but did not receive copies of their employment contracts, which were signed for a two-year term.
- After being deployed, the petitioners worked for four months without receiving their wages before seeking assistance from the Philippine Embassy and returning to the Philippines.
Procedural History
- Upon returning, petitioners filed a complaint with the Philippine Overseas Employment Administration (POEA) to recover their unpaid salaries and placement fees.
- The POEA's decision on June 30, 1989, ordered the respondent to refund the placement fees but dismissed the claims for unpaid salaries due to lack of merit.
- Both parties appealed the POEA's decision to the National Labor Relati