G & M (Phil.), Inc. v. Rivera
REITERATIONFacts
The Antecedents: G & M (Phil.), Inc. (petitioner) deployed Lorenzo Rivera, husband of respondent Zenas Rivera, to work in Saudi Arabia. Lorenzo died after working for 1 year, 7 months, and 17 days. Respondent filed a complaint for unpaid salary differentials, alleging Lorenzo was not paid his salary for 23 days before his death and that his monthly salary was below the contracted US$600. Procedural History: The Labor Arbiter ordered petitioner to pay unpaid salary, salary differential, and attorney's fees. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. The Court of Appeals denied petitioner's Petition for Certiorari, upholding the findings of the Labor Arbiter and NLRC. The Petition: Petitioner assailed the Court of Appeals' decision, arguing it gravely erred in applying the rule on burden of proof against petitioner and in holding there was no inconsistency between the OCW Information Sheet and the Final Settlement.
Issue(s)
Whether the Court of Appeals gravely erred in applying the rule on burden of proof against petitioner regarding the non-payment of salary. Whether the Court of Appeals erred in holding that there is no inconsistency between the salary of petitioner's husband appearing in the OCW Information Sheet and in the Final Settlement, and whether the petitioner presented sufficient evidence of payment.
Ruling
The Supreme Court denied the petition and affirmed the assailed Decision of the Court of Appeals. Costs were against the petitioner.
Ratio Decidendi
On the issue of burden of proof regarding non-payment of salary: The Court reiterated that in labor standards claims, the burden of proof rests upon the employer. Petitioner's argument that non-payment was not sufficiently shown was unmeritorious. The Court of Appeals correctly held that since petitioner and its foreign principals maintain the employment records, it was incumbent upon them to produce payrolls and vouchers to prove payment. Failure to present such evidence to controvert respondent's claim for salary differentials and unpaid salary for 23 days was fatal to petitioner's case. The OCW Info Sheet clearly stated Lorenzo Rivera ought to receive US$600.00 basic monthly salary, and petitioner failed to present any document to show actual payment as per the POEA approved contract. Therefore, it can be safely concluded that the deceased was not paid his monthly salary as per contract and his unpaid salaries were not given to him. On the issue of inconsistency in salary and sufficiency of evidence: The Court found no error in the Court of Appeals' conclusion that there was no inconsistency. The appellate court explained that the discrepancy was explained by the fact that aside from his monthly salary of SR 700, the deceased was also entitled to a monthly food allowance of SR 200 and monthly overtime pay of SR 200. This explanation, coupled with the petitioner's failure to present evidence of payment, supported the findings of the lower tribunals. The Court emphasized that it is not a trier of facts and generally defers to the factual findings of the Labor Arbiter, NLRC, and Court of Appeals when supported by substantial evidence, which was the case here.
Main Doctrine
In labor standards claims, the burden of proof rests upon the employer to present payrolls and vouchers to controvert the employee's claim for unpaid salaries and salary differentials, especially when the employer and its foreign principals maintain the employment records.