Datuman v. First Cosmopolitan Manpower
REITERATIONFacts
The Antecedents: Santosa B. Datuman was recruited by First Cosmopolitan Manpower and Promotion Services, Inc. to work in Bahrain as a saleslady with a monthly salary of US$370.00 for a one-year contract. Upon arrival, her employer allegedly withheld her passport and forced her to work as a domestic helper for BD40.00 (approximately US$100.00) per month. She was later compelled to sign a new contract transferring her to another employer as a housemaid for two years with the same reduced salary. From September 1991 to April 1993, she claims she worked without compensation. She returned to the Philippines in May 1993. Procedural History: In May 1995, Datuman filed a complaint with the POEA Adjudication Office for underpayment and nonpayment of salary, vacation leave pay, and refund of plane fare. She also filed a separate case with the National Labor Relations Commission (NLRC) for underpayment of salary, nonpayment of vacation pay, and reimbursement of return airfare. The Labor Arbiter ruled in favor of Datuman, ordering the respondent agency to pay salary differentials and plane ticket refund. The NLRC affirmed this decision with modification, reducing the salary differentials award based on prescription. The respondent agency then filed a petition for certiorari with the Court of Appeals (CA), which initially dismissed it for insufficiency but later reinstated it. The CA ultimately reversed the NLRC and Labor Arbiter decisions, finding the agency not liable and the claims prescribed. The Petition: Datuman filed a petition for review on certiorari under Rule 45 of the Rules of Civil Procedure, assailing the CA's decision. She argues that the CA erred in abandoning the factual findings of the Labor Arbiter and NLRC, in holding that the respondent agency is only privy to the principal contract, and in ruling that her cause of action had prescribed. She contends that the respondent agency is jointly and solidarily liable with the foreign employer for all claims arising from the implementation of the contract, and that her claims for salary differentials have not prescribed, as the prescriptive period should be counted from the accrual of each unpaid salary, not from the signing of a coerced contract.
Issue(s)
Whether the Court of Appeals erred in abandoning the factual findings of the Labor Arbiter as affirmed by the National Labor Relations Commission. Whether the Court of Appeals erred in holding that the respondent agency is only privy and liable to the principal contract. Whether the Court of Appeals erred in holding that the cause of action of the petitioner had already prescribed.
Ruling
The petition is GRANTED. The assailed Decision of the Court of Appeals dated August 7, 2002, and Resolution dated November 14, 2002, are REVERSED AND SET ASIDE. The Decision of the National Labor Relations Commission dated February 24, 2000, is REINSTATED with a qualification regarding the award of salary differentials.
Ratio Decidendi
On whether the Court of Appeals erred in abandoning the factual findings of the Labor Arbiter and NLRC: The Supreme Court held that the CA erred in disregarding the factual findings of the Labor Arbiter and NLRC, which were not disturbed by the CA itself. These findings established that petitioner was forced to work under oppressive conditions and that the "substitute" contracts were fabricated. The Court emphasized that the CA should have given due weight to the concurrent factual conclusions of the NLRC and the Labor Arbiter, especially when these were not contradicted by substantial evidence. The CA's reversal was based on a misinterpretation of the law regarding the liability of recruitment agencies, not on a lack of factual basis for the earlier rulings. The Court reiterated that the findings of labor tribunals, when supported by evidence, are generally binding on higher courts. On whether the respondent agency is only privy and liable to the principal contract: The Supreme Court ruled that the respondent agency is jointly and solidarily liable with the foreign employer for all claims arising from the implementation of the contract, as mandated by POEA Rules and Regulations. This liability is not limited to the original POEA-approved contract. The Court found that the signing of "substitute" contracts and the continuation of employment beyond the original term, against the petitioner's will, constituted continuing breaches of the original POEA-approved contract. To limit the agency's liability to the first contract would open the door to exploitation and contravene the State's policy of protecting overseas workers. The Court cited Placewell International Services Corporation v. Camote to emphasize that subsequent agreements reducing salaries below POEA-approved rates are void. On whether the petitioner's claims for underpaid salaries have prescribed: The Supreme Court disagreed with the CA's finding of prescription. It held that the three-year prescriptive period under Article 291 of the Labor Code should be reckoned from the time the salaries fell due, not from the date of signing the "substitute" contract. The Court clarified that the cause of action for salary differentials accrues as they fall due. Counting three years prior to the filing of the complaint on May 31, 1995, the Court determined that claims accruing prior to May 31, 1992, had prescribed. Therefore, petitioner was entitled to salary differentials for the period from May 31, 1992, to April 1993, which amounted to eleven months. The Court corrected the NLRC's computation period but affirmed the principle that claims do not prescribe if filed within the statutory period from when they become due.
Main Doctrine
Local recruitment agencies are jointly and solidarily liable with foreign employers for all claims and liabilities arising from the implementation of the employment contract, and this liability extends to breaches of the POEA-approved contract, including those resulting from the substitution or alteration of contracts to the prejudice of the worker.