Title
Princess Talent Center Production, Inc. vs. Masagca
Case
G.R. No. 191310
Decision Date
Apr 11, 2018
Overseas artist Masagca, deployed by PTCPI to South Korea, alleged unpaid wages, illegal dismissal, and forged loans. SC ruled in her favor, awarding unpaid salaries, placement fee reimbursement, and attorney’s fees, holding PTCPI, Moldes, and SAENCO jointly liable.

Case Summary (G.R. No. 191310)

Applicable Law and Jurisdiction

The case is governed by the 1987 Philippine Constitution and Republic Act No. 8042 (The Migrant Workers and Overseas Filipinos Act of 1995), including its amendments and implementing rules. The Constitution mandates protection for Filipino labor, including overseas workers, guaranteeing security of tenure, humane conditions of work, and due process in dismissal. The Labor Code provisions apply by virtue of lex loci contractus, as the employment contract was executed in the Philippines.

Employment Contract and Allegations of the Parties

The parties entered into a Model Employment Contract for Filipino Overseas Performing Artists to Korea on February 3, 2003, stipulating a six-month employment term, extendible by mutual agreement, with a monthly salary of at least US$600, work hours, rest days, and termination conditions. Respondent alleged she was misled into believing her contract was for one year, was made to sign documents without reading them, and worked beyond the original six-month period without receiving her salary except commissions. Respondent claimed illegal dismissal and demanded unpaid salaries, moral damages, and attorney’s fees.

Petitioners denied illegal dismissal, contending respondent knew and understood the six-month contract, which respondent completed. They argued that any contract extension was without their consent. Petitioners claimed respondent violated conduct rules at the workplace, was repatriated due to such violations, and that she was fully paid as evidenced by signed cash vouchers and co-worker affidavits. Petitioner Moldes disclaimed personal liability, acting merely as corporate officer.

Labor Arbiter’s Decision

The Labor Arbiter dismissed respondent’s complaint, emphasizing that:

  • The employment was for six months only, evidenced by the approved contract.
  • There was no proof of contract extension involving petitioners or POEA approval.
  • The vouchers showing salary payment were unchallenged in their authenticity by the respondent.
  • The respondent failed to prove nonpayment and entitlement to overtime pay.
    Accordingly, illegal dismissal and unpaid salary claims were denied.

NLRC’s Conflicting Decisions

On appeal, the NLRC initially ruled in favor of respondent, finding:

  • Respondent was not paid her regular salary.
  • Questionable authenticity of vouchers submitted by petitioners.
  • Petitioners condoned respondent’s nine-month employment, acknowledging overstaying.
  • Petitioners misrepresented employment terms and committed illegal dismissal.
  • Award of one year’s unpaid salary at US$600 per month.

However, upon reconsideration, the NLRC reversed itself due to procedural defects in respondent’s appeal but, on merits, ruled:

  • Respondent’s employment was for six months only.
  • No proof of contract extension or misrepresentation.
  • Respondent read and understood contract terms, and worked beyond approved period without consent of petitioners.
  • Salary payments were evidenced by vouchers and affidavits of co-workers.
  • Dismissal was due to contract expiration, not illegal.
    The NLRC reinstated the Labor Arbiter’s dismissal decision.

Court of Appeals’ Review and Ruling

The Court of Appeals excused respondent’s technical procedural lapses in appealing to NLRC and prioritized substantial justice. It ruled respondent was illegally dismissed without just cause and without procedural due process, holding petitioners and SAENCO jointly and severally liable for unpaid salaries and attorney’s fees. The Court reasoned that:

  • The burden to prove lawful dismissal rests on the employer and recruitment agency jointly.
  • Respondent was made to believe the contract was for one year; she worked for more than nine months, with petitioners’ knowledge and consent.
  • Respondent worked at a different venue than contracted, and received less salary than contracted, contrary to petitioner’s misrepresentations.
  • Allegations of misconduct were not substantiated.
  • Respondent was deprived of procedural due process, denied notice and hearing.
  • Petitioners and SAENCO must pay unpaid salaries for one year and attorney’s fees equal to 10% of monetary benefits.

Supreme Court’s Analysis: Scope of Review and New Evidence

The Supreme Court noted the case raised factual issues, typically beyond its scope on Rule 45 petitions, but allowed review due to conflicting findings from labor tribunals and Court of Appeals. It refused to entertain new evidence submitted by petitioners on appeal, emphasizing the requirement to present evidence in the proper venues and uphold due process and fairness. The Court reiterated that substantial evidence suffices in quasi-judicial proceedings and that the burden of proof lies with the party asserting an affirmative claim.

Security of Tenure and Lex Loci Contractus Principles

Invoking the 1987 Constitution’s Article XIII, Section 3, and settled jurisprudence, the Court reaffirmed security of tenure for overseas Filipino workers and the application of Philippine labor laws by reason of lex loci contractus, since the contract was made in the Philippines. Dismissal requires just or authorized cause and compliance with procedural due process, including written notice of charges and hearing opportunities.

Findings on Employment Duration and Extension

While the original employment contract was for six months, the Court found, as a matter of fact, that respondent continued employment beyond March 5, 2004, effectively extending the contract for an additional six months under the same terms, despite lack of formal written agreement on extension. Petitioners’ own conduct and knowledge, including Moldes’ intervention in June 2004, evidenced awareness and participation in the extended employment period.

Evaluation of Illegal Dismissal Claim

The Court determined the dismissal was illegal on both substantive and procedural grounds:

  • Substantively, petitioners and SAENCO failed to prove lawful cause for dismissal. Expired visa alone does not justify termination when employer is responsible for visa renewal and condoned respondent’s extended work. Allegations of misconduct were uncorroborated, unsupported by written policies, and contradicted by neutral testimony and documentary evidence.
  • Procedurally, petitioners and SAENCO did not comply with required two written notices and hearing before termination, violating respondent’s right to due process.

Payment of Salaries and Monetary Awards

Petitioners presented nine cash vouchers signed by respondent as evidence of salary payments from October 2003 to June 2004. The Court found respondent’s signatures genuine and shifted the burden to respondent to prove nonpayment, which she failed to do convincingly. The vouchers carried probative value absent strong contrary evidence. The Court found no basis to nullify the vouchers as the Court of Appeals had done.

The Court awarded respondent unpaid salaries for the unexpired three months (July-September 2004) of her e

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