- Petitioner
- Philippine National Construction Corporation
- Respondent
- The Honorable National Labor Relations Commission
- Citation
- G.R. No. 101535
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Campos, Jr., J.
- Decided
- January 22, 1993
Summary
Overseas workers filed complaint against Philippine National Construction Corporation for salary and benefit differentials, claiming entitlement to US$350/month per original POEA-approved contract rather than US$260/month per subsequently modified contract. POEA and NLRC ruled in favor of workers, finding that contract modification without Department of Labor approval violated Article 34(i) of the Labor Code. Supreme Court affirmed on certiorari, rejecting petitioner's claim of grave abuse of discretion. The Court applied the principle of liberal interpretation of labor contracts in favor of workers under Article 1702 of the Civil Code and social justice policy, emphasizing constitutional mandate for labor protection. The decision established that overseas employment contracts validated by POEA cannot be unilaterally modified by employers without proper government approval, and workers retain rights under originally approved contract terms.