CASE DIGEST
U R Employed
International Corp. v. Pinmiliw
G.R. No. 225263, [March 16, 2022]
THIRD, LOPEZ, M.
OFW Contracts of employment; illegal dismissal; finality to factual findings by Labor Arbiters
Courts generally accord respect and
finality to factual findings made by lower tribunals, especially when these
findings are supported by evidence and confirmed by higher courts. This
principle emphasizes the deference given to the expertise of labor agencies in
assessing evidence and resolving disputes in labor cases.
UR Employed International Corporation (UREIC) hired Mike A. Pinmiliw, Murphy P. Pacya, Simon M. Bastog, and Ryan D. Ayochok (collectively, respondents) as construction workers in Kota Kinabalu, Sabah, Malaysia, for its principal, The W Construction (TWC). The respondents' contracts were for two years with a basic monthly salary of RM800. However, upon their arrival in Malaysia, they faced adverse working conditions, including unsafe living conditions, unpaid overtime work, and the discovery that they only had tourist visas. Despite reporting their grievances to their broker and sending an email seeking assistance, their conditions did not improve. Eventually, Ryan was terminated, allegedly due to writing derogatory statements to the Baguio Midland Courier, while the other respondents were promised repatriation but were only sent home later. The respondents filed a complaint for illegal dismissal and money claims against UREIC and its administrator, Pamela T. Miguel.
Whether the respondents were illegally
dismissed and entitled to monetary claims against UREIC and Pamela T. Miguel.
YES. The Labor Arbiter (LA) found that the respondents
were constructively dismissed due to the unbearable working conditions set by
the employer, and Ryan's termination lacked procedural and substantive due
process. The LA awarded the respondents backwages, refund of placement fees,
damages, and attorney's fees but dismissed claims for overtime pay and illegal
deductions, except for one respondent, Mike, who presented proof of illegal
deductions. The National Labor Relations Commission (NLRC) affirmed the LA's decision.
The Court of Appeals (CA) dismissed UREIC's petition for certiorari, affirming
the NLRC's ruling. The CA emphasized the relaxed application of technical rules
in labor cases and upheld the substantial evidence of illegal dismissal. The
Supreme Court (SC) denied UREIC's petition, ruling that the doctrines of
primary administrative jurisdiction and immutability of judgment did not apply.
The SC affirmed the lower courts' findings of illegal dismissal and upheld the
monetary awards, which would earn legal interest at 6% per annum until fully
paid.

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