Sagun v. Sunace International (G.R. No. 179242; February 23, 2011)


FACTS: Petitioner applied with respondent for the position of caretaker in Taiwan. In consideration of her placement and employment, petitioner allegedly paid P30,000.00 cash, P10,000.00 in the form of a promissory note, and NT$60,000.00 through salary deduction, in violation of the prohibition on excessive placement fees.

The complaint for lack of merit. Specifically, the POEA Administrator found that petitioner failed to establish facts showing a violation of Article 32, since it was proven that the amount received by respondent (only P20,840.00) as placement fee was covered by an official receipt, and because respondent processed petitioner’s papers as caretaker, the position she applied and was hired for.

The Secretary of Labor and the Office of the President partially granted petitioner’s motion for reconsideration, as they found that there was indeed collection of excessive fees. The appellate court reversed the rulings of the Secretary of Labor and the OP mainly because their conclusions were based not on evidence but on speculation, conjecture, possibilities, and probabilities.ISSUE: Did the CA err in granting the respondent’s petition for review reversing the decision of the Office of the President?

HELD: The POEA and the CA are correct in dismissing the complaint for illegal exaction filed by petitioner against respondent.

In proceedings before administrative and quasi-judicial agencies, the quantum of evidence required to establish a fact is substantial evidence, or that level of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.

In this case, the pieces of evidence presented by petitioner are not substantial to show that respondent collected from her more than the allowable placement fee. In support of her allegation, she presented a photocopy of a promissory note she executed, and testified on the purported deductions made by her foreign employer. The Court thus gave more credence to respondent’s evidence, that is, the acknowledgment receipt showing the amount paid by petitioner and received by respondent. Although a receipt is not conclusive evidence, an exhaustive review of the records of this case fails to disclose any other evidence sufficient and strong enough to overturn the acknowledgment embodied in respondent’s receipt as to the amount it actually received from petitioner. DENIED.