G.R. No. 109808 March 1, 1995
ESALYN CHAVEZ, petitioner, vs. HON. EDNA BONTO-PEREZ, HON. ROGELIO T. RAYALA, HON. DOMINGO H. ZAPANTA, HON. JOSE N. SARMIENTO, CENTRUM PROMOTIONS PLACEMENT CORPORATION, JOSE A. AZUCENA, JR., and TIMES SURETY & INSURANCE COMPANY, INC., respondents.

FACTS

On December 1, 1988, petitioner Esalyn Chavez, an entertainment dancer, entered into a standard employment contract for overseas Filipino artists with Planning Japan Co., Ltd., through its Philippine representative, private respondent Centrum Placement & Promotions Corporation. The POEA-approved contract stipulated a monthly salary of US$1,500.00 for a duration of two to six months. Subsequently, on December 10, 1988, petitioner executed a side agreement with her Japanese employer through her local manager, Jaz Talents Promotion, authorizing a deduction of US$250.00 from a contracted monthly salary of US$750.00, leaving her with a net monthly salary of US$500.00. Petitioner worked in Osaka, Japan, for six months, from December 16, 1988, to June 10, 1989. Almost two years later, on February 21, 1991, she filed a complaint with the POEA for underpayment of wages, seeking US$6,000.00 in unpaid salary differentials. The POEA Administrator dismissed the complaint, citing petitioner’s satisfaction with her employment, her consent to the side agreement, and her being in bad faith and estopped from claiming the original salary. The Administrator also invoked laches due to her nearly two-year delay in filing the complaint and noted that Jaz Talents Promotion was not a licensed agency. The NLRC affirmed this decision.

ISSUE

Whether public respondents committed grave abuse of discretion in dismissing petitioner’s complaint based on the findings that: (1) she is guilty of laches; (2) the side agreement superseded the standard employment contract; and (3) the respondents are not solidarily liable for her unpaid wages.

RULING

Yes, the Supreme Court granted the petition, reversing the decisions of the POEA Administrator and the NLRC. The Court held:
1. The side agreement reducing petitioner’s salary to US$750.00 is null and void. It violated the minimum employment standards set by the POEA and was executed without POEA approval, contravening the stipulation in the standard contract that any alteration without prior POEA approval is void. The agreement was an exploitative scheme against a helpless overseas worker.
2. The doctrine of laches does not apply. Laches is not based on mere lapse of time but on the inequity of enforcing a stale claim. Petitioner filed her money claim within the three-year prescriptive period under Article 291 of the Labor Code. Her delay did not prejudice the respondents, and her disadvantaged status as a poor, uncounselled overseas worker explained her inaction.
3. Private respondents are jointly and severally liable with the foreign employer for petitioner’s unpaid wages. The standard employment contract contained a solidary liability clause, and the law mandates that the local agency acts as an agent of the foreign principal, making them solidarily liable for violations of the employment contract.
The Court ordered private respondents to pay petitioner jointly and severally the amount of US$6,000.00 in unpaid wages.