G.R. No. 112096 ; January 30, 1996
MARCELINO B. AGOY, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, EUREKA PERSONNEL MANAGEMENT SERVICES, INC., ET. AL., respondents.

FACTS

Petitioner Marcelino Agoy was deployed by respondent agency Eureka to work for respondent Al-Khodari in Saudi Arabia under a contract for a “CE/Road Engineer” position. Upon arrival, he was instead made to work as a “Road Foreman” under different salary terms. He was later pressured to sign a new contract with a reduced salary or face termination. Upon his refusal, he was dismissed. Petitioner executed a “Final Settlement” and a termination letter indicating his agreement, after which he was repatriated. He subsequently filed a complaint for illegal dismissal.
The POEA initially dismissed his complaint, finding his consent to termination voluntary. The NLRC, on appeal, reversed the POEA, declaring the dismissal illegal and awarding salary for the unexpired contract. However, upon motions for reconsideration, the NLRC reinstated the POEA’s dismissal ruling. Petitioner now assails this NLRC Resolution via certiorari, alleging grave abuse of discretion.

ISSUE

Whether the NLRC committed grave abuse of discretion in reinstating the POEA decision and upholding the validity of petitioner’s dismissal.

RULING

Yes. The Supreme Court granted the petition, finding that the NLRC gravely abused its discretion. The legal logic centers on the burden of proof in dismissal cases and the validity of quitclaims. The employer bears the burden to prove that a dismissal is for a just or authorized cause. Here, the purported ground was petitioner’s failure to meet performance standards during the probationary period. However, private respondents failed to substantiate what these standards were or how petitioner failed to meet them. Mere allegation is insufficient.
Furthermore, documents like the “Final Settlement” and termination letter, indicating petitioner’s consent, do not automatically validate the dismissal. The Court emphasized that quitclaims executed by employees are often frowned upon as they are usually signed under exploitative circumstances, especially for overseas workers in a foreign land. Petitioner’s immediate filing of a complaint upon repatriation negates any notion of voluntary consent. Since the employer failed to discharge its burden of proving a valid dismissal, the termination is deemed illegal. Consequently, the NLRC’s reversal of its own sound decision, which awarded petitioner his salaries for the unexpired portion of his contract, constituted grave abuse of discretion. The Court reinstated the NLRC’s earlier decision granting the monetary award.