Sunace International Management Services v. National Labor Relations Commission

Summary

This case involves liability of overseas recruitment agency for claims arising from extended employment contract. Divina Montehermozo was deployed to Taiwan as domestic helper under 12-month contract through Sunace International Management Services. After contract expiration, she worked two more years through direct arrangement with employer. Upon return, she claimed non-refund of salary deductions totaling NT91,950.00. Labor Arbiter and NLRC ruled for Divina, finding Sunace impliedly consented to extension. Court of Appeals affirmed. Supreme Court reversed, ruling no substantial proof of Sunace's knowledge or consent to extension. Court applied Civil Code provisions on agency, finding implied revocation when principal directly negotiated with employee. The decision clarifies limits of recruitment agency liability for unauthorized contract extensions and proper application of agency law principles in overseas employment cases.