Santa Fe Construction Co. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents were hired by petitioner Santa Fe International Services, Inc. (SFISI), through its local agent Santa Fe Construction Co. (SFCC), for a one-year contract to work on an off-shore oil rig in Luanda, Angola. Their employment commenced between March and May 1987. On December 1, 1987, SFISI allegedly granted private respondents a fifteen-day vacation leave with pay, and prepared their papers and plane tickets, advancing transportation expenses. However, their salaries for November 1987 were not paid. Upon inquiring about their return to work, private respondents were informed by SFCC that their employment had been terminated. Procedural History: Private respondents filed a complaint with the Philippine Overseas Employment Administration (POEA) for back wages, overtime pay for November 1987, salaries for the unexpired portion of their contracts, and moral and exemplary damages. The POEA found the termination illegal, rejecting petitioners' contention of mass resignation and ordering payment of unpaid salaries and salaries for the unexpired portion of contracts, but denying damages. Petitioners appealed to the National Labor Relations Commission (NLRC), which affirmed the POEA decision. The NLRC found that two private respondents worked during the period petitioners claimed they refused to work and considered doubtful the advance of transportation expenses given the alleged mass resignation. The NLRC also ruled that the award should be paid in Philippine currency at the exchange rate prevailing at the time of accrual of the cause of action (December 1987), citing Republic v. Laureano Bros., Inc.. The Petition: Petitioners filed a petition for certiorari under Rule 65 of the Rules of Court, assailing the NLRC resolution. They argued that the NLRC committed grave abuse of discretion in not giving weight to their evidence of mass resignation, contending that only individual resignation letters and the physical production of passports would suffice as proof. They also questioned the acceptance of unauthenticated photocopies of timecards and argued that their claim of mass resignation was supported by the accounts of twenty-two fellow contract workers. Regarding repatriation expenses, they stated they were merely complying with POEA rules.
Issue(s)
Whether respondent NLRC committed grave abuse of discretion in affirming the POEA decision that the dismissal of private respondents was illegal. Whether the evidence presented by petitioners sufficiently established a case of mass resignation by private respondents. Whether the timecards of respondents Cañete and Detuya, presented as unauthenticated photocopies, were admissible and sufficient evidence. Whether the NLRC erred in ruling that the award should be paid in Philippine currency at the exchange rate prevailing at the time the cause of action accrued.
Ruling
The petition is DISMISSED, and the questioned Resolution of respondent National Labor Relations Commission dated April 19, 1991, is AFFIRMED. The temporary restraining order issued on September 2, 1991, is LIFTED.
Ratio Decidendi
On whether respondent NLRC committed grave abuse of discretion in affirming the POEA decision that the dismissal of private respondents was illegal: The Court held that petitioners failed to establish grave abuse of discretion on the part of the NLRC. The rule is settled that the Court's review of NLRC decisions under Rule 65 is confined to issues of jurisdiction or grave abuse of discretion, not the correctness of its evaluation of evidence. Petitioners must satisfactorily prove that the NLRC acted capriciously and whimsically, disregarding evidence material to the controversy. In this case, the NLRC's findings were supported by substantial evidence of record and conformed to law and jurisprudence. The findings of administrative agencies with expertise are generally accorded respect and finality. On whether the evidence presented by petitioners sufficiently established a case of mass resignation by private respondents: The Court found that the NLRC correctly ruled that petitioners failed to present sufficient evidence of mass resignation. The NLRC noted that two of the private respondents, Jaime F. Cañete and Tito L. Detuya, worked on November 27, 28, 29, and 30, 1987, contradicting petitioners' allegation of refusal to work starting November 27, 1987. Furthermore, the NLRC considered the petitioners' act of advancing transportation expenses for the private respondents' trip to Manila as extraordinary generosity, especially if they knew the private respondents instigated a mass resignation, casting doubt on the petitioners' claim. On whether the timecards of respondents Cañete and Detuya, presented as unauthenticated photocopies, were admissible and sufficient evidence: The Court agreed with the Solicitor General that the timecards were properly considered. The Solicitor General pointed out that the operations manager of SFISI himself reported in the timecards that Cañete and Detuya did work between November 27 and 30, 1987. If petitioners doubted the authenticity of the photocopies, they should have presented the original copies. Their failure to do so meant that the presented copies were faithful reproductions of the originals. The Court also noted that it was understandable why not all private respondents took copies of their timecards, especially if they left Angola believing they would return after their vacation leave. On whether the NLRC erred in ruling that the award should be paid in Philippine currency at the exchange rate prevailing at the time the cause of action accrued: The NLRC correctly ruled that the payment of the award in Philippine currency should be at the rate of exchange prevailing at the time the cause of action of private respondents accrued, or at the time they were illegally terminated in December 1987, citing Republic v. Laureano Bros., Inc.. This ruling prevents the employer from benefiting from currency devaluation between the time of illegal termination and the actual payment of the award, ensuring fair compensation to the employees.
Main Doctrine
The Supreme Court affirmed the NLRC's finding that the dismissal of private respondents was illegal, holding that petitioners failed to present sufficient evidence of mass resignation and that the NLRC did not commit grave abuse of discretion in its evaluation of the evidence.