G.R. No. 179242 ; February 23, 2011
AVELINA F. SAGUN, Petitioner, vs. SUNACE INTERNATIONAL MANAGEMENT SERVICES, INC., Respondent.

FACTS

Petitioner Avelina F. Sagun filed a complaint with the Philippine Overseas Employment Administration (POEA) against respondent Sunace International Management Services, Inc. for alleged violations of the Labor Code. She claimed that in August 1998, she applied with respondent for a caretaker position in Taiwan. In consideration for her placement, she allegedly paid ₱30,000.00 in cash, executed a ₱10,000.00 promissory note, and had NT$60,000.00 deducted from her salary, which she asserted were excessive placement fees. She also alleged that respondent misrepresented her job, as she worked as a domestic helper and in a poultry farm instead of as a caretaker. Respondent denied the allegations, maintaining it only collected the authorized fee of ₱20,840.00, for which an official receipt was issued, and that it did not furnish any false information. The POEA Administrator dismissed the complaint for lack of merit, finding no violation of Article 32 (fees) or Article 34(a) (excessive fees) and (b) (false information) of the Labor Code. Petitioner filed a motion for reconsideration with the Office of the Secretary of Labor, which was treated as a petition for review. The Secretary partially granted it, holding respondent liable for collecting an excessive placement fee under Article 34(a), ordering a refund of ₱10,000.00 and NT$65,000.00, and imposing a fine or license suspension. The Office of the President affirmed this order. On respondent’s appeal, the Court of Appeals reversed the decisions of the Secretary of Labor and the Office of the President, reinstated the POEA’s dismissal, and found a lack of sufficient evidence. Petitioner elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in granting the respondent’s petition for review and reversing the decision and order of the Office of the President, specifically on the issue of respondent’s liability for collecting an excessive placement fee under Article 34(a) of the Labor Code.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petitioner failed to present substantial evidence to prove that respondent collected an excessive placement fee. The quantum of evidence required in administrative proceedings is substantial evidence. Respondent presented an acknowledgment receipt showing it received only ₱20,840.00 from petitioner, the authorized amount. Petitioner’s evidence—a photocopy of a promissory note for ₱10,000.00 and her testimony about salary deductions of NT$60,000.00 by her foreign employer—was insufficient to overturn the primary evidence of the receipt. The promissory note is a formal commitment to repay a debt and does not conclusively prove it was part of a placement fee. The fact that respondent is not a lending company does not preclude it from extending a loan. Allegations regarding salary deductions by the foreign employer were unsubstantiated and did not directly implicate respondent in collecting an excessive fee. The POEA and the Court of Appeals correctly found no violation of Article 34(a). The Court emphasized that a receipt, while not conclusive, stands as the best evidence absent strong rebuttal. Consequently, the complaint for illegal exaction was properly dismissed for lack of merit.