G.R. No. 181919; July 20, 2011
Jones International Manpower Services, Inc., represented by its President, Edward G. Cue, Petitioner, vs. Bella Agcaoili-Barit, Respondent.

FACTS

Respondent Bella Agcaoili-Barit filed a complaint for non-payment of salaries and refund of transportation fare against petitioner Jones International Manpower Services, Inc. (the agency). She was deployed as a domestic helper to Mohamad Hameed Al-Naimi in Saudi Arabia under a two-year contract (July 23, 1999 to July 23, 2001) with a monthly salary of US$200. She alleged she was paid only US$100 monthly and, starting January 2001, was not paid at all. She extended her employment for another 10 months at the employer’s request but was still not paid. She left the employer in May 2002, had a live-in relationship with another Filipino worker, was arrested under Saudi law, imprisoned for over a year, and was released and repatriated in October 2003. She then demanded payment of unpaid salaries, wage differentials, and airfare refund.
The agency defended that the contract expired in July 2001 without complaint, was extended with her consent, and that she left without permission. It argued it had no liability for the extended period, that all wages were paid, and that final wages and belongings were turned over to Saudi authorities upon her imprisonment for a non-employment related offense.
The Labor Arbiter awarded Barit salary differentials (July 1999-December 2000) and unpaid salaries (January 2001-July 2001), but absolved the agency for the extended period. The NLRC reversed, dismissing the complaint but awarding ₱10,000 as financial assistance for equity, doubting Barit would extend employment if unpaid. The Court of Appeals reinstated the Labor Arbiter’s award, holding the agency and foreign principal solidarily liable, and found the employer’s letters claiming full payment insufficient without supporting evidence like payrolls.

ISSUE

1. Whether the Labor Arbiter and the Court of Appeals erred in awarding salary differentials for underpayment of wages when such claim was not explicitly stated as a cause of action in the complaint, allegedly violating NLRC rules.
2. Whether the Court of Appeals erred in disregarding the evidence presented by the agency (employer’s letters) to prove full payment of wages.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals Decision.
1. On the first issue: The claim for underpayment of wages (salary differentials) is included within the cause of action for “non-payment of salaries” as stated in the complaint. The Court held that “non-payment of salaries” encompasses both the complete non-payment and the underpayment of wages. The rules of procedure should be liberally construed to serve the ends of substantial justice, especially in labor cases. Barit’s position paper, which detailed the underpayment, was a proper amplification of the cause of action in her complaint. The Labor Arbiter did not err in considering it.
2. On the second issue: The employer’s letters, which were self-serving and unsubstantiated, were insufficient to prove payment. The burden of proof rests on the employer to show payment of wages. The mere allegation of payment in letters, without corroborating evidence such as payrolls, receipts, or quitclaims, does not discharge this burden. The Court found no reason to disturb the factual findings of the Labor Arbiter and the Court of Appeals, which are accorded respect and finality. The solidary liability of the recruitment agency and the foreign principal for the awarded claims was upheld.
The dispositive portion ordered the petitioner agency and its foreign principal to pay respondent solidarily the awarded amounts.