G & M (Phils.) v. Cruz
REITERATIONFacts
The Antecedents: Respondent Epifanio Cruz was recruited by petitioner G & M (Phils.), Inc. to work as a trailer driver for its foreign principal in Saudi Arabia for two years with a stipulated monthly salary of US$625. Upon arrival, respondent alleged he was made to sign a blank contract, his salary was reduced to SR604.00, and he was deported after seven months. Respondent claimed his dismissal was due to complaints about sub-human working conditions, non-payment of wages and overtime, salary deductions, and employer changes. He further alleged he only received five months' salary and was not paid for the last two months of his employment. Procedural History: Respondent filed a complaint with the Labor Arbiter for illegal dismissal, underpayment, and non-payment of wages, and refund of transportation expenses. The Labor Arbiter denied the illegal dismissal claim but ordered petitioner to pay respondent P77,455.00 and US$1,250.00 or its peso equivalent. Petitioner partially appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal and ordered petitioner and its foreign principal jointly and severally liable for salary differentials and unpaid salaries totaling US$3,125.00 less SR3,020.00 and US$1,250.00. Petitioner then filed a special civil action for certiorari with the Court of Appeals, which was also dismissed for lack of merit. The Petition: Petitioner filed a petition for review on certiorari under Rule 45 of the Rules of Court, arguing that the Court of Appeals erred by failing to consider that the respondent's admission of receiving payments shifted the burden of proof to him to demonstrate underpayment, and that the payroll issue was of great importance. Petitioner contended that the pay slip submitted by respondent was of questionable authenticity and insufficient to prove underpayment. The Supreme Court found that the petition primarily involved factual issues regarding the evidence supporting the lower tribunals' findings on salary differentials and unpaid wages, which it generally does not re-examine. The Court affirmed that the burden of proving payment rests on the employer, and petitioner failed to present controverting evidence to prove full payment.
Issue(s)
Whether the Court of Appeals erred in not considering that the respondent's admission of receiving payments shifted the burden of proof to him to show concrete proof of underpayment, and whether the payroll issue is of great importance in determining the issues of the case. Whether the pay slip submitted by the respondent is admissible as evidence.
Ruling
The petition is denied for lack of merit. The findings of the Labor Arbiter, NLRC, and Court of Appeals that the respondent was not fully paid of his wages are upheld.
Ratio Decidendi
On the burden of proof, the payroll issue, and shifting burdens: The Court reiterated the well-entrenched rule that findings of fact of quasi-judicial bodies, when supported by substantial evidence and upheld by the Court of Appeals, are binding and conclusive upon the Supreme Court. The Court found no reason to depart from this doctrine. It clarified that the burden of proving payment of monetary claims rests on the employer, in this case, the petitioner as the recruitment agency. Petitioner's contention that respondent's admission of receiving some payments shifted the burden of proof was rejected. The Court held that respondent's admission of receiving SR604.00 as monthly salary did not discharge petitioner from proving full payment of the stipulated US$625.00. Petitioner failed to present controverting evidence to prove full payment, thus defaulting in its defense and effectively admitting the allegations of underpayment. The Court emphasized that the employer has the burden of establishing payments beyond those admitted by the employee. On the admissibility of the pay slip: The Court affirmed the admissibility of the pay slips, noting that proceedings before the NLRC are not governed by strict technical rules of evidence. Both the Labor Arbiter and the NLRC found the pay slips admissible. The NLRC justified their admission as original duplicates of computerized payslips issued by the employer, containing itemized earnings and deductions. The Court found no arbitrariness or lack of rational basis in the NLRC's ruling on admissibility, stating that the fact that the payslips were not authenticated did not militate against the complainant's claim, especially since their presentation established the fact of underpayment, shifting the burden to the respondent to prove full compensation.
Main Doctrine
In labor cases, findings of fact of quasi-judicial bodies, like the NLRC, are accorded respect and even finality if supported by substantial evidence, and are binding upon the Supreme Court when passed upon and upheld by the Court of Appeals. The burden of proving payment of monetary claims rests on the employer.