Cadalin v. POEA

Facts:
The case "Cadalin v. Administrator, Philippine Overseas Employment Administration" involves a

class suit initiated by Bienvenido M. Cadalin, Rolando M. Amul, Donato B. Evangelista, and 1,767
other overseas contract workers (OCWs).
The suit was filed against Asia International Builders Corporation (AIBC) and Brown & Root
International Inc. (BRII) on June 6, 1984, with the Philippine Overseas Employment
Administration (POEA).
The claimants sought compensation for the unexpired portion of their employment contracts,
interest on unpaid benefits, area wage and salary differential pay, fringe benefits, and other
monetary claims.
Initially, the POEA awarded monetary benefits to only 149 claimants and dismissed certain
claims due to a lack of substantial evidence or proof of employment.
The case was appealed to the National Labor Relations Commission (NLRC), which modified the
POEA's decision and directed further hearings for some claims.
The case was eventually elevated to the Supreme Court, leading to the consolidation of multiple
petitions filed by both the claimants and the respondents.
Facts 2:
Cadalin et al. are Filipino workers recruited by Asia Int’l Builders Co. (AIBC), a domestic
recruitment corporation, for employment in Bahrain to work for Brown & Root Int’l Inc. (BRII)
which is a foreign corporation with headquarters in Texas. Plaintiff instituted a class suit with the
POEA for money claims arising from the unexpired portion of their employment contract which
was prematurely terminated. They worked in Bahrain for BRII and they filed the suit after 1 yr.
from the termination of their employment contract.
As provided by Art. 156 of the Amiri Decree aka as the Labor Law of the Private Sector of
Bahrain: “a claim arising out of a contract of employment shall not be actionable after the lapse
of 1 year from the date of the expiry of the contract,” it appears that their suit has prescribed.
Issue:
1. WON the foreign law should govern or the contract of the parties.(WON the complainants who
have worked in Bahrain are entitled to the above-mentioned benefits provided by Amiri Decree
No. 23 of Bahrain).
2. WON the Bahrain Law should apply in the case. (Assuming it is applicable WON complainants’
claim for the benefits provided therein have prescribed.)
3. Whether or not the instant cases qualify as; a class suit (siningit ko nalang)
(the rest of the issues in the full text of the case refer to Labor Law)
Ruling:
The Supreme Court dismissed all the petitions, thereby upholding the NLRC's decision.
The Court ruled that the prescriptive period for filing the claims is three years under the Labor
Code.
It determined that the labor cases do not qualify as a class suit.

The proceedings conducted by the POEA and the NLRC adhered to the requirements of due
process.
The Court found no grave abuse of discretion i...
Ratio:
The Court held that the prescriptive period for filing money claims arising from employer-
employee relations is three years under Article 291 of the Labor Code, rather than ten years
under Article 1144 of the Civil Code.
The claims stemmed from the employer-employee relationship, which is broader in scope than
claims arising from a specific law or contract.
The Court concurred with the NLRC that the labor cases do not qualify as a class suit
Case Background and Parties Involved
The case of Cadalin v. Administrator, Philippine Overseas Employment Administration involves a

class suit filed by overseas contract workers against Asia International Builders Corporation
(AIBC) and Brown and Root International Inc. (BRII) for money claims.
The case was filed by Bienvenido M. Cadalin, Rolando M. Amul, Donato B. Evangelista, and
1,767 other named complainants, represented by their attorney-in-fact, Atty. Gerardo A. Del
Mundo.
The claimants sought payment for the unexpired portion of their employment contracts, as well
as various other benefits and reimbursements.
Stages of Proceedings and Motions
The case went through several stages of proceedings, including motions, appeals, and petitions.
The claimants argued that AIBC and BRII had waived their right to present evidence and had
defaulted by failing to file their answers and attend the pre-trial conference.
AIBC and BRII appealed to the National Labor Relations Commission (NLRC), seeking the
reversal of the POEA's decision.
The NLRC modified the decision of the POEA, dismissing some claims and granting others.
The claimants and AIBC and BRII filed motions for reconsideration, which were denied by the
NLRC.
Compromise Agreements and Dismissal of Claims
Throughout the proceedings, the claimants and AIBC and BRII entered into several compromise
agreements, which were approved by the court.
These agreements resulted in the dismissal of the claims of certain claimants.
Key Issues Raised in the Case
The issues raised in the case included the entitlement of the claimants to benefits provided by
Amiri Decree No. 23 of Bahrain, the prescription of the claims, the classification of the case as a
class suit, the compliance with due process, the jurisdiction and liability of AIBC and BRII, and
the dismissal of certain claims.
NLRC Rulings on Key Issues

The NLRC ruled that the claimants were entitled to benefits provided by Amiri Decree No. 23 of
Bahrain, but only for those who worked in Bahrain.
The NLRC also held that the prescriptive period for the claims was three years.
The NLRC agreed with the POEA Administrator that the case could not be treated as a class suit
because not all the claimants worked in Bahrain.
The NLRC found that there were violations of due process in the proceedings and that AIBC and
BRII were solidarily liable for the claims.
The NLRC also held that jurisdiction over BRII was acquired through the summons served on
AIBC.
Court's Decision and Rulings on Petitions
The Court held that the right to a speedy disposition of cases is a relative term and that the
delay in the proceedings was not unreasonable or arbitrary.
The Court dismissed the claimantscontinue reading

Cadalin v. POEA

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Facts:

The case "Cadalin v. Administrator, Philippine Overseas Employment Administration" involves a

It determined that the labor cases do not qualify as a class suit.

The Court found no grave abuse of discretion i...

Case Background and Parties Involved

The case of Cadalin v. Administrator, Philippine Overseas Employment Administration involves a

Stages of Proceedings and Motions

Compromise Agreements and Dismissal of Claims

These agreements resulted in the dismissal of the claims of certain claimants.

Key Issues Raised in the Case

NLRC Rulings on Key Issues

Court's Decision and Rulings on Petitions

The Court dismissed the claimantscontinue reading

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