Case Summary (G.R. No. 169973)
Factual Background
On August 15, 1999, PISC deployed Camote to work as a building carpenter for SAAD Trading and Contracting Co. in KSA under a two-year contract with a salary of US$370.00 per month. However, upon reporting to the job site, Camote was reportedly deemed incompetent and was pressured to consent to a lower salary of SR 800.00 per month, which he accepted to avoid losing his job. Subsequently, he filed a sworn complaint alleging several violations including the coercion to sign a new contract written in Arabic, reduced salary, unpaid overtime, and lack of support from the Philippine Embassy.
Labor Arbiter's Decision
On May 31, 2002, Labor Arbiter Arturo L. Gamolo ruled that the modification of Camote's employment contract violated Section 10 of Republic Act No. 8042. The labor arbiter determined that Camote was entitled to the original monthly salary of US$370.00. The decision also reviewed the claims for overtime and denied them on the grounds of existing payments that took into account the modified salary rate. Camote was awarded a total of P215,424.00 for underpayment and attorney’s fees.
NLRC Ruling
Upon appeal, the National Labor Relations Commission (NLRC) vacated the labor arbiter's decision, dismissing Camote's case for lack of a cause of action. The NLRC's ruling supported the notion that Camote’s acceptance of the new contract was voluntary and, therefore, valid.
Court of Appeals’ Analysis
Camote sought a remedy in the Court of Appeals, which reversed the NLRC's ruling, reinstating the labor arbiter's decision with modifications. The appellate court found that the salary reduction from US$370.00 to SR 800.00 breached Section 10 of R.A. No. 8042. It noted the lack of substantiated claims regarding Camote's alleged incompetence and determined that PISC failed to demonstrate valid reasons for the salary demotion.
Petitioner’s Arguments and Higher Court Considerations
In its petition, PISC argued that Camote had not substantiated claims of coercion regarding the new employment contract and raised defenses based on laches and unauthorized deductions. The petition highlighted that laches was inapplicable due to the reasonable time frame in which Camote filed his complaints. PISC further contended that the claim for unauthorized deductions was unfounded.
Ruling on Salary Alteration and Attorney’s Fees
The Supreme Court reaffirmed that under R.A. No. 8042, unauthorized modifications to an employment contract that disadvantage the worker are void, thus upholding Camote's right to his origin
...continue readingCase Syllabus (G.R. No. 169973)
Case Background
- This case revolves around a Petition for Review on Certiorari filed by Placewell International Services Corporation (PISC) against Ireneo B. Camote.
- The petition contests the September 27, 2005 Decision of the Court of Appeals in CA-G.R. SP No. 77145, which overturned the November 20, 2002 Resolution of the National Labor Relations Commission (NLRC) and reinstated, with modifications, the May 31, 2002 Decision of Labor Arbiter Arturo L. Gamolo.
Employment Contract and Allegations
- On August 15, 1999, PISC deployed Camote as a building carpenter to SAAD Trading and Contracting Co. in the Kingdom of Saudi Arabia under a two-year contract with a salary of US$370.00 per month.
- Camote was later deemed incompetent by his employer, leading to a decision to terminate his services; however, he successfully negotiated to remain employed at a reduced salary of SR 800.00 per month.
- On November 27, 2001, Camote filed a sworn Complaint against PISC, alleging coercion to sign a new employment contract in Arabic and claimed he received a reduced salary and was denied overtime pay despite working nine hours daily.
- Camote asserted that attempts to seek assistance from the Philippine Embassy were unsuccessful due to communication barriers.
Labor Arbiter's Decision
- On May 31, 2002, the Labor Arbiter ruled that modifying Camote’s employment contract was illegal under Section 10 of Republic Act No. 8042 (R.A. No. 8042), affirming he was entitled to his original salary of US$370.00 per month.
- The Arbiter also