G.R. No. 160123 , June 17, 2015.
CENTRO PROJECT MANPOWER SERVICES CORPORATION, Petitioner, vs. AGUINALDO NALUIS and THE COURT OF APPEALS, Respondents.

FACTS

Petitioner Centro Project Manpower Services Corporation (Centro Project), a local recruitment agency, engaged respondent Aguinaldo Naluis to work abroad as a plumber under Pacific Micronesia Corporation in Saipan, Northern Mariana Islands. The primary Employment Contract dated March 11, 1997, stipulated a 12-month employment term. An addendum executed on September 3, 1997, made the start of employment effective from his departure. Naluis was deployed on September 13, 1997. The Department of Labor and Immigration of Northern Mariana Islands had issued an Authorization for Entry (AE) on June 3, 1997. Naluis was repatriated to the Philippines on June 3, 1998, without completing the 12-month contract. He filed a complaint for illegal dismissal. The Labor Arbiter and the NLRC dismissed the complaint, ruling that repatriation was justified due to the laws and regulations of Northern Mariana Islands as provided in the AE, which they interpreted as limiting his stay. The Court of Appeals reversed the NLRC, holding that the AE did not limit Naluis’ stay and that Centro Project breached the contract by ordering his repatriation. Centro Project appealed to the Supreme Court.

ISSUE

Whether the expiration date contained in the Authorization for Entry (AE) issued by the immigration authorities of Northern Mariana Islands validly cut short Naluis’ employment contract and justified his repatriation.

RULING

No. The Supreme Court denied the appeal and affirmed the Court of Appeals’ decision. The Court held that the AE did not limit Naluis’ stay in Northern Marianas; the date “May 13, 1998” appearing on the AE referred only to the expiration of the document itself. Item number 3 of the AE recognized that the entry permit, if issued for employment, expires automatically upon termination of such employment, implying no pre-set limitation of stay contrary to the employment contract’s 12-month term. In interpreting labor contracts, doubts are resolved in favor of the laborer. Centro Project failed to discharge its burden of proof to show that the repatriation was justified. Its fear that Naluis would be declared an illegal alien was unsubstantiated and imaginary. Furthermore, Centro Project’s claim that the expiration date was inserted by a Philippine representative without its participation was unsupported by credible proof and, even if true, demonstrated bad faith for not amending the contract or informing Naluis despite knowing the stipulated 12-month term. Thus, Naluis’ repatriation constituted a breach of the employment contract. The Court affirmed the CA’s award of four months’ salary for the unexpired portion, guaranteed overtime pay, placement fee reimbursement, holiday pay, vacation leave pay, and attorney’s fees.