G.R. No. 149285 . August 30, 2006. GODOFREDO MORALES, Petitioner, vs. SKILLS INTERNATIONAL COMPANY AND/OR MAHER DAAS AND MARIVIC DAAS AND/OR WALLAN AL WALLAN, Respondents.
FACTS

Petitioner Godofredo Morales filed a complaint for illegal dismissal and monetary claims against his foreign employer, Wallan Al Wallan, and respondent recruitment agency, Skills International Company. He alleged that after being previously deployed by Skills International, he met his new employer, Wallan Al Wallan, at the agency’s office in 1996 and was subsequently processed for overseas employment under the government’s Balik Manggagawa program. His employment was terminated in April 1997. Skills International denied liability, asserting that Wallan Al Wallan was not its accredited principal and that it merely facilitated Morales’s redeployment as a returning worker, not under a new agency-hired contract.
The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the complaint against Skills International, finding no employer-agency relationship. The Court of Appeals affirmed, holding that Morales failed to prove that Skills International was his recruitment agency for the disputed employment.

ISSUE

Whether respondent Skills International Company can be held solidarily liable with the foreign employer for petitioner’s monetary claims arising from his alleged illegal dismissal.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Court ruled that for a recruitment agency to be held solidarily liable with a foreign employer under the Migrant Workers Act, the employer must be the agency’s accredited principal. Here, petitioner failed to substantiate that Wallan Al Wallan was an accredited principal of Skills International for his 1996 deployment. The evidence showed he was processed as a “balik-manggagawa” or returning worker, which applies to workers resuming employment with the same employer, not those securing new contracts through agency recruitment. His possession of a standard employment contract unsigned by the agency and a medical referral were insufficient to establish an agency relationship, as he did not present a verified job order or proof of payment of a placement fee. Since the foreign employer was not proven to be Skills International’s principal, the agency could not be held liable. The claims remained solely against the foreign employer.