Manuela S. Catan/M.S. Catan Placement Agency v. The National Labor Relations Commission

Summary

This case establishes the solidary liability of placement agencies for overseas Filipino workers beyond the termination of their agency agreements with foreign principals. Francisco D. Reyes, recruited by M.S. Catan Placement Agency to work in Saudi Arabia, was injured while operating machinery. The Supreme Court affirmed that placement agencies remain liable for employment contract violations until the actual expiration of workers' employment contracts, not merely until termination of the agency agreement with foreign principals. The Court applied estoppel principles, noting that the agency facilitated the worker's return to Saudi Arabia, thereby certifying his fitness to work. This decision strengthens protection for OFWs by ensuring continuous liability of recruitment agencies throughout the employment period, preventing agencies from escaping obligations by terminating principal relationships while workers remain employed abroad.