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Termination of Employment: Procedural Requirements - Decision/Award - A decision, especially an appeal, should directly meet the issues for resolution.

It
76 ABD Overseas Manpower Corp v. NLRC is immaterial that the NLRC is a quasi-judicial body and not a regular court
February 24, 1998 | Romero, J. | YES. MARS was the accredited recruitment agency at the time of the complaint
Doctrine: Under Article 8, sec 14.- No decision shall be rendered by any court without - An accreditation transferee assumes the contractual responsibility of the
expressing therein clearly and distinctly the facts and the law on which it is based.” transferor under all circumstances, without qualification.
It is a requirement of due process that the parties to a litigation be informed of - However, a strict application of this rule will result in a grave injustice to ABD.
how it was decided, with an explanation of the factual and legal reasons that led to the They became liable only after the issues had be met in the illegal dismissal case
conclusions of the court against MARS.
Facts: - ABD became the accredited recruitment agency of the principal, M.S. Al Babtain
● December, 1989 - . Mohmina Macaraya applied as a dressmaker with Mars Recruitment Office, on September 3, 1990, after MARS had filed on July 5, 1990,
International Manpower Inc. (MARS). She signed a 2 year contract with MARS its answer to Macaraya’s complaint for illegal dismissal
and would be paid 250 dollars as monthly salary. - ABD only got involved on January 9, 1992 when it was impleaded through
● However, without her knowledge, MARS submitted to POEA an overseas MARS’ motion.
contract worker information sheet stating that she would be employed as a - Under the Rules of Court which were then in effect and applicable to the case at
domestic helper for two years with a monthly salary of 200 dollars. bar, when MARS failed to file an answer to petitioner’s crossclaim, it should have
● She was then deployed to Riyadh Saudi Arabia, and her employer took the only been declared in default with respect to such claim.
copy of her contract and never returned to her. She was made to work as a - However, technical rules of procedure are not applicable in labor cases, but may
domestic helper despite her objections. After 3 months and 13 days, she was apply only by analogy or in a suppletory character
dismissed and only paid 700 Saudi Royals. - Hence, when the POEA opted to overlook petitioner’s crossclaim against MARS,
● Upon her return to the Philippines, she filed a complaint with POEA for illegal petitioner was denied substantial justice
dismissal against MARS. - MARS impleaded ABD after the case had been submitted for decision and 1 and
● MARS filed a manifestation on January 9, 1992 that ADB became the accredited half years after MARS filed its answer.
recruitment agency. - MARS should not be totally cleared if its liability to Macaraya as they were the
● POEA ruled that Macaraya had been illegally dismissed with ABD, being the ones whom Macaraya had entered into a contract with and so they should be
accredited agency, assuming complete responsibility to the contractual obligation accountable for her claims.
of the principal MS Al Babtain Recruitment Office. - However, the court ruled that ABD shall pay Macaraya her claims following the
● On appeal to the NLRC, the NLRC dismissed the appeal as well as the MR. POEA decision but this is without prejudice to ABD’s right to be reimbursed by
● In their petition for certiorari, ABD alleges that the NLRC merely quoted the MARS.
findings of POEA, and that they were only impleaded 1 and half years after
MARS filed an answer to Macaraya’s complaint. Dispositive
WHEREFORE, the resolutions of the NLRC dated March 21, 1994, and August 10, 1994,
Issue: are hereby AFFIRMED, subject to the modification that respondent Mars International
W/N ABD was denied due process Manpower, Inc. shall reimburse
W/N MARS is liable as the recruitment agency. petitioner ABD Overseas Manpower Corporation the amount awarded therein to
respondent Mohmina Macaraya. This Decision is immediately executory. No costs.
Held: SO ORDERED.
YES.
- The NLRC left ABD “in the dark” by its failure to discuss why the facts it pointed
out in its memorandum on appeal would not affect the POEA rules
- Under Article 8, sec 14.- No decision shall be rendered by any court without
expressing therein clearly and distinctly the facts and the law on which it is
based.”
- It is a requirement of due process that the parties to a litigation be informed of
how it was decided, with an explanation of the factual and legal reasons that led
to the conclusions of the court