G.R. No. 86042 ; April 30, 1991
Feagle Construction Corporation, petitioner, vs. Mauro Dorado, Eduardo Librando, Reynaldo Decepido, Dionisio Bergonia, Renato Tiangco, Eugenio Macawili, Salvador Ardeza and National Labor Relations Commission, respondents.

FACTS

Private respondents were overseas workers in Saudi Arabia employed by Algosaibi-Bison, Ltd. (AB). In 1983, AB encountered financial difficulties, delaying salary remittances, though all salaries were ultimately paid before the workers’ return to the Philippines. Petitioner Feagle Construction Corporation, the local agent, had previously shouldered mobilization expenses without reimbursement from AB due to its financial state, leading petitioner to cease redeploying workers. In July 1984, the private respondents, then jobless in the Philippines, urgently requested petitioner to redeploy them to AB despite the known risks. They assured petitioner they would assume all risks regarding delayed or unpaid salaries and signed individual waivers expressly releasing petitioner from liability for any claims arising from AB’s obligations.
While redeployed, the workers received salaries directly from AB. When AB declared bankruptcy in 1986, the workers filed claims directly with the Saudi liquidator, who issued certificates for amounts due, to be paid preferentially under Saudi law. Petitioner merely assisted by following up these claims. Nevertheless, the workers filed a complaint against petitioner with the Philippine Overseas Employment Administration (POEA) for unpaid wages.

ISSUE

Whether petitioner Feagle Construction Corporation can be held jointly and severally liable with the foreign principal, Algosaibi-Bison, Ltd., for the unpaid salaries of the private respondents, notwithstanding the waivers of liability they executed.

RULING

The Supreme Court ruled in favor of the petitioner, setting aside the NLRC decision. The Court held that the waivers signed by the private respondents were valid and binding under the specific circumstances. The legal logic is that when workers, fully aware of their principal employer’s precarious financial condition and after explicit warnings from the local agent, voluntarily insist on redeployment and expressly assume the risk by signing unambiguous waivers, they thereby relieve the local agent from solidary liability for claims arising from the foreign employer’s subsequent failure to pay.
The Court emphasized that the waivers were not obtained through deceit or coercion but were a product of the workers’ desperate insistence to work despite known dangers. Furthermore, the workers had already pursued their claims directly against the foreign principal’s liquidator under Saudi law, obtaining a commitment for payment. Holding petitioner liable would constitute unjust enrichment, allowing double recovery. Thus, the local agent cannot be held jointly and severally liable where the workers knowingly assumed the risk and released the agent from responsibility through a clear waiver.