In labor disputes regarding unpaid wages, the Supreme Court affirms that the burden of proving payment lies with the employer, not the employee. Even if an employee admits to receiving partial payment, the employer must still demonstrate that they fully paid the stipulated salary. This ruling protects employees from potential underpayment and ensures employers maintain proper records of wage disbursements, reinforcing the principle that employers bear the responsibility of proving they have met their contractual obligations regarding wages.

Shortchanged Abroad: Who Carries the Weight of Proof in Overseas Wage Disputes?

G & M (Phils.), Inc. recruited Epifanio Cruz to work as a trailer driver in Saudi Arabia, promising a monthly salary of US$625. Upon arrival, Cruz claimed he was forced to sign a blank contract, and his salary was reduced to SR604. After seven months, he was deported, allegedly for complaining about poor working conditions and wage discrepancies. Cruz filed a complaint against G & M (Phils.), Inc. for illegal dismissal and underpayment of wages. The Labor Arbiter partially ruled in Cruz’s favor, a decision affirmed by the NLRC and later by the Court of Appeals. This legal battle reached the Supreme Court, centering on which party bore the responsibility of proving whether Cruz received the wages he was originally promised.

At the heart of the matter is the **burden of proof**—who must demonstrate the validity of their claims. In wage disputes, the responsibility falls squarely on the employer. The Supreme Court emphasized that it is the employer’s duty to provide concrete evidence that the employee received the full compensation as stipulated in their agreement. This stems from the principle that employers are expected to maintain accurate records of employee wages and disbursements.

The Court of Appeals pointed out that G & M (Phils.), Inc. failed to provide adequate evidence to prove the salaries paid to Cruz aligned with the original agreement. Even though Cruz admitted to receiving some payment, the obligation to demonstrate full compliance remained with the company. The Supreme Court referenced the precedent set in Jimenez vs. NLRC, stating that “one who pleads payment has the burden of proving it. Even where the plaintiff must allege non-payment, the general rule is that the burden rests on the defendant to prove payment, rather than on the plaintiff to prove non-payment.”

Furthermore, the Court addressed the admissibility of the pay slips presented by Cruz as evidence. While G & M (Phils.), Inc. questioned their authenticity, the NLRC considered them valid, original duplicates of computerized pay slips. The Labor Code’s Article 221 clarifies that NLRC proceedings are not strictly bound by technical rules of evidence, granting the NLRC discretion in evaluating the probative value of submitted documents.

“… the payslips are original duplicates of computerized payslips issued by the employer… The fact that the payslips are not authenticated will not militate against complainant’s claim, considering that in presenting the payslips, complainant has established the fact of underpayment, and the burden has shifted to the respondent to prove that complainant was totally compensated for actual services rendered.”

The Supreme Court affirmed the lower courts’ findings, underscoring the principle that employers carry the burden of proving payment in wage disputes. This decision reaffirms protections for employees, particularly overseas workers, against potential exploitation through wage manipulation. It reinforces the need for employers to keep transparent, detailed records of employee compensation.

FAQs

What was the central issue in this case?	The core issue was determining which party bears the burden of proving wage payments in a labor dispute: the employer or the employee.
Who has the burden of proof in wage disputes?	The Supreme Court ruled that the employer carries the burden of proving that the employee was paid the full wages as agreed upon in their employment contract.
Does the employee’s admission of partial payment change the burden of proof?	No, even if the employee admits to receiving partial payments, the employer still has the responsibility to prove that they paid the remaining balance of the agreed-upon salary.
What kind of evidence is required to prove wage payment?	Employers must present concrete evidence, such as payroll records, deposit slips, or other documents that demonstrate the wages paid to the employee.
Are pay slips admissible as evidence?	Yes, the NLRC deemed the payslips submitted by Cruz admissible.
What is the significance of Article 221 of the Labor Code?	Article 221 of the Labor Code states that the NLRC is not strictly bound by technical rules of evidence, which gives it discretion to determine the admissibility and probative value of evidence presented.
What was the outcome of this case?	The Supreme Court affirmed the Court of Appeals’ decision, ordering G & M (Phils.), Inc. to pay Epifanio Cruz his unpaid salary and salary differentials.
Why is this ruling important for overseas Filipino workers (OFWs)?	This ruling is crucial for OFWs because it strengthens their protection against wage exploitation by ensuring that employers are held accountable for proving full payment of agreed salaries.

This case clarifies the responsibilities of employers to maintain diligent records of employee compensation, and emphasizes that proving compliance with wage agreements rests firmly on the employer. This provides essential safeguards for employees in wage disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: G & M (PHILS.), INC. vs. EPIFANIO CRUZ, G.R. NO. 140495, April 15, 2005