Case Summary (G.R. No. 229984)
Applicable Law and Procedural History
The 1987 Philippine Constitution governs the case based on decision date (July 8, 2020). Relevant laws include Republic Act No. 8042 (Migrant Workers and Overseas Filipinos Act of 1995), as amended by Republic Act No. 10022, which governs the protection and welfare of overseas Filipino workers (OFWs), and labor jurisprudence on constructive dismissal. The case was initially ruled upon by the Labor Arbiter, appealed to and reversed by the National Labor Relations Commission (NLRC), further appealed to the Court of Appeals (CA), and finally elevated by certiorari to the Supreme Court of the Philippines.
Facts and Chronology of Events
Jacob was deployed abroad in January 2015 under a two-year contract with a monthly salary of US$400. On January 31, 2015, Jacob experienced sexual harassment when her male employer allegedly attempted rape. Reporting the incident to her female employer resulted in disbelief and subsequent maltreatment, including a physical assault on February 16, 2015. Feeling unsafe, Jacob escaped to the agency’s counterpart office but had to flee again through a window, sustaining a spinal injury in the fall. Medical records confirm surgery and treatment in Saudi Arabia. After repatriation arrangements facilitated by the Overseas Workers Welfare Administration (OWWA) and the Philippine Overseas Labor Office (POLO), Jacob executed a Final Settlement and Certification stating she voluntarily agreed to return home and that she received all due compensation. However, she later contested the validity of her signature on the settlement and filed a complaint for constructive dismissal, maltreatment, and unpaid wages.
Issues Presented
The core issue for resolution was whether Jacob was constructively dismissed from employment, rendering the Final Settlement void and entitling her to compensation and damages. Secondary issues involved the validity of the Final Settlement executed abroad and whether the petitioner voluntarily resigned or was forced to leave due to intolerable working conditions.
Findings of the Labor Arbiter
The Labor Arbiter ruled in favor of Jacob, finding constructive dismissal based on the detailed and categorical narration of maltreatment, including attempted rape, physical abuse, and intolerable working conditions by foreign employers. The Labor Arbiter gave little weight to the Final Settlement, noting its contested authenticity and that it was a mere photocopy. The Labor Arbiter ordered respondents to pay her wages for the unexpired contract period but denied claims for medical expenses and damages due to lack of supporting evidence at that point.
NLRC Decision
The NLRC reversed the Labor Arbiter, dismissing the complaint for lack of merit. It held that the Final Settlement and Certification executed before the Philippine Embassy were valid, invoking the presumption of regularity in official acts of the Labor Attaché. The NLRC emphasized lack of convincing proof that the settlement was forged or involuntary and considered the absence of police or medical reports substantiating maltreatment or harassment allegations.
Court of Appeals Ruling
The CA upheld the NLRC decision, dismissing the petition and affirming the validity of the Final Settlement. The CA found inconsistencies in Jacob’s account, absence of prior complaints to authorities overseas, and ruled that the alleged maltreatment and attempted rape were not substantiated. The CA accorded weight to the Labor Attaché’s certification that petitioner personally appeared and signed the settlement.
Issues on Constructive Dismissal and Evidentiary Considerations
The Supreme Court reversed the CA ruling, finding grave abuse of discretion in disregarding the totality of evidence supporting Jacob’s claim of constructive dismissal. It clarified that constructive dismissal includes situations where employment is rendered unbearable by the employer’s acts, even without explicit termination or diminution of benefits. The petitioner’s detailed sworn declaration, supported by medical records documenting injury sustained during escape, was held as substantial evidence corroborating maltreatment and justifying her departure.
Validity of Final Settlement and Jurisdiction of Philippine Embassy
The Court emphasized that the Final Settlement was not conclusive proof of voluntary resignation since it was signed under duress as a condition for repatriation. The certification marked “seen and noted” by the Labor Attaché did not amount to attestation of its truthfulness by Jacob. The absence of a witness and petitioner’s denial of the authenticity of her signature further weakened respondents’ position. It noted that deeds of waiver or quitclaims executed under coercion or without full understanding are generally disfavored and may not bar employees from asserting their labor rights.
Burden of Proof on Resignation vs. Dismissal
Citing established labor law jurisprudence, the Court reaffirmed that when an employer alleges voluntary resignation, they bear the burden of proving such resignation was voluntary and not coerced. Respondents failed to meet this burden satisfactorily, relying heavily on the Final Settlement and uncorroborated assertions of homesickness. Petitioner’s consistent allegations supported by medical and contextual evidence outweighed respondents’ conclusory claims.
Award of Damages and Attorney’s Fees
The Court granted moral damages (P50,000) and exemplary damages (P25,000) due to the bad faith, oppressive, and humiliating circumstances surrounding
...continue readingCase Syllabus (G.R. No. 229984)
Facts and Background
- Donna B. Jacob, a Filipina, sought employment as a household service worker through First Step Manpower International Services, Inc., signing a two-year contract to work in Riyadh, Kingdom of Saudi Arabia, with a monthly salary of US$400.
- She was deployed abroad on January 11, 2015, and assigned to the residence of her foreign employers, Abdulaziz Masser Abdulaziz Al Masoud and his wife.
- Within less than three months, Jacob experienced serious maltreatment: attempted sexual assault by her male employer on January 31, 2015, which she reported to her female employer, who disbelieved and mistreated her.
- Physical abuse followed, including being hit and having a shoe violently thrown at her by the female employer on February 16, 2015, prompting her escape to the agency’s counterpart office in Riyadh.
- Alongside another overseas Filipino worker (OFW), Rosalie Bermido, Jacob attempted to escape the agency premises, falling and injuring her spinal column.
- She was admitted to King Saud Medical City for surgery on February 28, 2015, and was later assisted by the Overseas Workers Welfare Administration (OWWA) representatives for repatriation.
- On March 25, 2015, she executed a Final Settlement and Certification before the Philippine Labor Attaché at the Philippine Embassy in Riyadh, agreeing to return to the Philippines and waiving the right to file complaints against the employer or agency.
- Jacob was repatriated to the Philippines on March 31, 2015.
Procedural History
- On July 2, 2015, Jacob and Bermido filed a complaint for constructive illegal dismissal, maltreatment, and nonpayment of wages.
- The Labor Arbiter initially found Jacob constructively dismissed due to unbearable treatment and awarded unpaid salary for the unexpired contract duration; Bermido’s complaint was dismissed for failure to prosecute.
- Respondents appealed to the National Labor Relations Commission (NLRC), submitting the Final Settlement and Certification with a Labor Attaché’s certification of authenticity.
- The NLRC reversed the Labor Arbiter’s finding, dismissing Jacob’s complaint for lack of merit, holding the Final Settlement valid and the dismissal claim untenable.
- Commissioner Nograles dissented, affirming constructive dismissal due to hostile working conditions and emphasizing that the settlement was signed under duress and as a condition for repatriation.
- Jacob filed a Petition for Certiorari before the Court of Appeals, which dismissed the petition, declaring her allegations unsubstantiated and giving evidentiary weight to the Final Settlement and Labor Attaché certification.
- A Motion for Reconsideration by Jacob was denied by the Court of Appeals.
- Jacob elevated the case to the Supreme Court via a Petition for Review on Certiorari.
Issues Presented
- Whether petitioner Donna B. Jacob was constructively dismissed from her overseas employment.
- Whether the Final Settlement and Certification signed by Jacob were valid and binding.
- Whether Jacob voluntarily resigned or was forced to leave due to maltreatment and unsafe conditions.
- Entitlement to damages and attorney’s fees consequent to illegal dismissal.
- Applicability of interest on monetary awards under Republic Act No. 10022.
Legal Principles and Definitions
- Constructive dismissal (or constructive discharge) occurs when harsh, hostile, and unfavorable working conditions compel an employee to leave involuntarily; it does not require an explicit termination or reduction in rank/pay.
- The test for constructive dismissal is whether a reasonable person in the employee’s position would be impel