The Supreme Court ruled that an applicant’s voluntary withdrawal of their application from a recruitment agency negates claims of misrepresentation and non-issuance of receipts against that agency. This decision emphasizes that unsubstantiated allegations without supporting evidence cannot override documented actions, such as a signed withdrawal form. This ruling protects recruitment agencies from liability when applicants later pursue employment through other channels after formally withdrawing their initial applications, provided the agency can demonstrate the withdrawal.

Application Withdrawal: Can Agencies Be Liable for Misrepresentation?

In LNS International Manpower Services v. Armando C. Padua, Jr., the Supreme Court addressed whether a recruitment agency could be held liable for misrepresentation and non-issuance of receipts after an applicant had formally withdrawn their application. Armando Padua, Jr. filed a complaint against LNS International Manpower Services (LNS) and Sharikat Al Saedi International Manpower (Sharikat), alleging that LNS misrepresented job opportunities and failed to provide receipts for fees paid. LNS countered by presenting a withdrawal letter signed by Padua, stating he had withdrawn his application. The central legal question was whether Padua’s claims could stand despite his acknowledged withdrawal of application from LNS.

The POEA initially found LNS liable, a decision affirmed by the DOLE and the Court of Appeals (CA). The CA gave more weight to Padua’s claim that he paid fees to LNS, assuming LNS would process his employment abroad. However, the Supreme Court reversed these decisions, emphasizing the importance of substantial evidence and the implications of a voluntarily signed withdrawal form. The court underscored that bare allegations are insufficient to prove liability when concrete evidence, such as the withdrawal form, contradicts those claims.

The Supreme Court’s decision hinged on the principle that factual findings must be supported by substantial evidence. As the Court elucidated, bare and unsubstantiated allegations do not hold probative value:

Bare and unsubstantiated allegations do not constitute substantial evidence and have no probative value.

In this case, Padua’s claims of misrepresentation and non-issuance of receipts were not supported by any concrete evidence other than his own statements. LNS, on the other hand, presented a signed withdrawal form, which Padua admitted to signing. This form served as tangible evidence that Padua had withdrawn his application, thus weakening his claims against LNS.

Building on this principle, the Court addressed the implications of signing a legal document voluntarily. When a person voluntarily signs a document, they are generally bound by its terms. The Court referenced a related case on this matter:

When he voluntarily signed the document, respondent is bound by the terms stipulated therein.

In the context of the present case, by signing the withdrawal form, Padua was bound by its implication—that he had indeed withdrawn his application from LNS. This withdrawal undermined his subsequent claims that LNS was responsible for his employment arrangements or any related issues.

The Court also scrutinized Padua’s claim that he signed the withdrawal form based on LNS’s representation that his papers would be endorsed to Sharikat. The Court found this assertion illogical. It questioned why LNS would require Padua to formally withdraw his application if their intention was simply to pass his papers to another agency. The act of withdrawal implies a cessation of the application process with LNS, making it contradictory for LNS to then endorse those withdrawn papers elsewhere.

Furthermore, the Court examined the timeline of events. Padua claimed he paid processing and medical fees to LNS in August 2002. However, the withdrawal form was dated July 27, 2002. The court found it illogical that Padua would pay fees to LNS after he had already withdrawn his application. This timeline discrepancy further eroded Padua’s credibility and supported LNS’s claim that it did not receive any payments from him.

The Supreme Court also addressed the lack of evidence linking LNS to Sharikat. Padua claimed that LNS endorsed his documents to Sharikat, but he provided no proof to support this claim. The Court reiterated that bare allegations, unsupported by evidence, are insufficient to prove a claim. It contrasted Padua’s unsubstantiated claim with the withdrawal form, which LNS presented as evidence and Padua did not dispute. Sharikat itself admitted that they were responsible for Padua’s deployment. Therefore, it was more plausible that Padua paid fees to Sharikat, not LNS.

The principle of finality of judgments also played a role in this case. The POEA had absolved Sharikat of any liability, and Padua did not appeal this decision. As such, the Court held that the judgment was final and binding on Padua concerning Sharikat’s involvement. This meant that Padua could not claim LNS was liable for actions that were ultimately carried out by Sharikat, which had already been cleared of any wrongdoing by the POEA.

In conclusion, the Supreme Court emphasized that to succeed in a claim, a party must present credible evidence. The Court stated:

In fine, for failure to adduce any shred of evidence of payment made to petitioner, or that petitioner referred or endorsed respondent for employment abroad to another agency, the charges of non-issuance of receipt and misrepresentation against petitioner could not possibly prosper.

The Court found that Padua failed to provide sufficient evidence to support his claims against LNS. Consequently, the Court reversed the CA’s decision and dismissed the complaint against LNS.

FAQs

What was the key issue in this case?	The key issue was whether LNS International Manpower Services could be held liable for misrepresentation and non-issuance of receipts after Armando Padua, Jr. had voluntarily withdrawn his application from the agency.
What did Armando Padua, Jr. allege in his complaint?	Padua alleged that LNS misrepresented job opportunities, failed to provide receipts for fees he paid, and that he was ultimately deployed by another agency, Sharikat, under unfavorable employment conditions.
What evidence did LNS present in its defense?	LNS presented a withdrawal letter signed by Padua, confirming that he had withdrawn his application from LNS before his deployment by Sharikat.
Why did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the decision because Padua’s claims were unsubstantiated, and he failed to provide sufficient evidence to support his allegations against LNS, especially in light of the withdrawal letter.
What is the significance of the withdrawal letter in this case?	The withdrawal letter was significant because it served as concrete evidence that Padua had terminated his application process with LNS, undermining his subsequent claims against the agency.
Did the Court find any logical inconsistencies in Padua’s claims?	Yes, the Court found it illogical that Padua would pay fees to LNS after withdrawing his application and questioned why LNS would require a formal withdrawal if they intended to endorse his papers to another agency.
How did the principle of finality of judgments affect the case?	The principle of finality affected the case because the POEA had absolved Sharikat of any liability, and Padua did not appeal this decision, making it binding and preventing him from shifting the blame to LNS for Sharikat’s actions.
What is the legal principle regarding unsubstantiated allegations?	The legal principle is that unsubstantiated allegations, without supporting evidence, do not constitute substantial evidence and have no probative value in proving a claim.
What was the final ruling of the Supreme Court?	The Supreme Court granted the petition, reversed the Court of Appeals’ decision, and dismissed the complaint against LNS International Manpower Services for lack of merit.

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: LNS International Manpower Services v. Padua, G.R. No. 179792, March 05, 2010