G.R. No. 225263 . March 16, 2022.
UR EMPLOYED INTERNATIONAL CORPORATION AND PAMELA T. MIGUEL, PETITIONERS, VS. MIKE A. PINMILIW, MURPHY P. PACYA, SIMON M. BASTOG, AND RYAN D. AYOCHOK, RESPONDENTS.

FACTS

Petitioners UR Employed International Corporation (UREIC) and its administrator Pamela T. Miguel hired respondents Mike A. Pinmiliw, Murphy P. Pacya, Simon M. Bastog, and Ryan D. Ayochok as construction workers in Kota Kinabalu, Malaysia for a two-year contract with a basic monthly salary of RM800. Upon arrival, their passports were taken, and they were subjected to unsafe and crowded living conditions with poor sanitation and ventilation. They worked beyond regular hours without pay and later discovered they only had tourist visas and no work permits, causing their principal to hide them from authorities. After their grievances were ignored, Ryan sent an email to a newspaper seeking assistance. In late August 2011, they were questioned about the email and were informed of their termination on September 13, 2011, with promised repatriation on September 15, 2011, which did not occur until November 2011, during which their food supply was cut off. Respondents filed a complaint for illegal dismissal and money claims. The Labor Arbiter ruled in favor of respondents, finding constructive dismissal and awarding backwages, refund of placement fees, damages, and attorney’s fees. The NLRC affirmed the decision. The Court of Appeals dismissed petitioners’ certiorari petition, upholding the labor tribunals’ rulings. Petitioners argue before the Supreme Court that the CA erred in not finding grave abuse of discretion by the NLRC and LA for violating the doctrines of primary administrative jurisdiction and immutability of judgment, citing a prior POEA case filed by respondents which was dismissed and became final.

ISSUE

Whether the Court of Appeals erred in not declaring that the NLRC and LA committed grave abuse of discretion by violating the doctrines of primary administrative jurisdiction and immutability of judgment, in light of a prior final POEA order dismissing a similar complaint by the respondents.

RULING

No. The petition is bereft of merit. The doctrine of primary jurisdiction does not denote exclusive jurisdiction and applies where enforcement of a claim requires resolution of issues within the special competence of an administrative body, suspending the judicial process pending referral. In this case, the respondents’ complaints before the POEA and the Labor Arbiter involved different causes of action and reliefs. The POEA case was for violation of recruitment rules and regulations, while the labor case was for illegal dismissal and money claims. These are distinct matters falling under the separate jurisdictions of the POEA (administrative) and the NLRC (labor relations). The finality of the POEA order does not bar the labor case due to the difference in the nature of the actions and the reliefs sought. The labor tribunals did not commit grave abuse of discretion, and their findings, affirmed by the CA, are supported by substantial evidence. The awards for backwages, refund of placement fees, damages, and attorney’s fees stand.