Jones International Manpower Services v. Agcaoili-Barit

G.R. No. 181919 (July 20, 2011)

Bella Agcaoili-Barit's unpaid salary claims were dismissed; Supreme Court affirmed NLRC ruling.

Facts:

On November 21, 2003, Bella Agcaoili-Barit filed a complaint against Jones International Manpower Services, Inc. for non-payment of salaries and refund of transportation fare. Barit had entered into a two-year employment contract with the agency for its foreign principal in Saudi Arabia, Mohamad Hameed Al-Naimi, as a domestic helper, with a stipulated salary of US$200.00 per month. However, she was only paid US$100.00 per month and, starting January 2001, she received no salary at all. Despite this, she extended her employment for an additional ten months at Hameed's request, as her replacement had not yet been deployed.

Frustrated with her situation, Barit left Hameed on May 29, 2002, and entered into a live-in relationship with another Filipino worker, Thomas Ambrosio, which was against Saudi law. She was subsequently arrested and imprisoned for over a year. After converting to Islam, she was released on October 14, 2003, and returned to the Philippines the following day. Upon her return, she demanded payment for her unpaid salaries for one year and four months, wage differentials from July 1999 to December 2000, and a refund for her airfare.

In defense, the agency contended that Barit's employment contract expired on July 23, 2001, and that she had consented to an extension. They argued that Barit left her employer without permission and was reported missing, asserting that Hameed could not assist her due to her violation of Saudi marital law. The agency denied liability for Barit's claims, asserting that all wages due were paid and that her final wages were turned over to the Saudi authorities.

Legal Issues:

  1. Whether Barit was underpaid or not paid her wages during her employment in Saudi Arabia.
  2. Whether Jones International Manpower Services, Inc. is solidarily liable with Hameed for Barit's claims of unpaid wages and wage differentials.

Arguments:

Petitioner's Arguments (Jones International Manpower Services, Inc.):

  • The agency argued that Barit's contract expired on July 23, 2001, and that she had not raised any complaints during her employment.
  • They contended that Barit voluntarily extended her contract despite alleged non-payment, which was illogical if she was indeed underpaid.
  • The agency claimed that it had no involvement in the alleged extension of Barit's employment and that it was not liable for her airfare refund.
  • They asserted that Barit had received her full wages, as evidenced by letters from Hameed stating that all salaries and benefits were paid.

Respondent's Arguments (Bella Agcaoili-Barit):

  • Barit argued that the agency's claims were mere semantics, asserting that her complaint encompassed both non-payment and underpayment of wages.
  • She maintained that the burden of proof for payment lies with the employer and the recruitment agency, and that the letters from Hameed were self-serving and lacked evidentiary value.
  • Barit contended that the agency failed to provide substantial evidence of payment, and that her employer's letters could not substitute for proper documentation like payslips or payrolls.

Court's Decision and Legal Reasoning:

The Court found merit in the petition filed by Jones International Manpower Services, Inc. It noted that there was a conflict between the findings of the Court of Appeals (CA) and the National Labor Relations Commission (NLRC). The Court reexamined the evidence and concluded that Barit had not been underpaid or unpaid during her employment.

The Court highlighted that Barit had not raised any complaints regarding her salary situation while in Saudi Arabia and had left her employer for personal reasons, not due to wage exploitation. It found substantial basis in the NLRC's conclusion that Barit had received her full salaries for the duration of her original contract. The Court also noted that the agency had made efforts to secure necessary documents from Hameed to dispute Barit's claims, and that the absence of payslips or payrolls was understandable given the nature of domestic work.

Ultimately, the Court ruled that the NLRC did not commit grave abuse of discretion in dismissing Barit's complaint, and thus, the CA erred in granting her petition for certiorari. The decision of the NLRC was reinstated.

Significant Legal Principles Established:

  • The burden of proof regarding the payment of wages lies with the employer and, in cases involving overseas workers, also with the recruitment agency.
  • The nature of domestic work may not always allow for formal documentation of wage payments, and the absence of such documentation does not automatically imply non-payment.
  • The context of the employment relationship, including the circumstances leading to the employee's departure, is crucial in determining liability for wage claims.