4/1/2020
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evidence required to establish a fact is substantial evidence, or that level of relevant
evidence which a reasonable mind might accept as adequate to justify a conclusion.[14]
In this case, are the pieces of evidence presented by petitioner substantial to show that
respondent collected from her more than the allowable placement fee? We answer in
the negative.
To show the amount it collected as placement fee from petitioner, respondent presented
an acknowledgment receipt showing that petitioner paid and respondent received
P20,840.00. This notwithstanding, petitioner claimed that she paid more than this
amount. In support of her allegation, she presented a photocopy of a promissory note
she executed, and testified on the purported deductions made by her foreign employer.
In the promissory note, petitioner promised to pay respondent the amount of
P10,000.00 that she borrowed for only two weeks.[15] Petitioner also explained that her
foreign employer deducted from her salary a total amount of NT$60,000.00. She
claimed that the P10,000.00 covered by the promissory note was never obtained as a
loan but as part of the placement fee collected by respondent. Moreover, she alleged
that the salary deductions made by her foreign employer still formed part of the
placement fee collected by respondent.
We are inclined to give more credence to respondent's evidence, that is, the
acknowledgment receipt showing the amount paid by petitioner and received by
respondent. A receipt is a written and signed acknowledgment that money or goods
have been delivered.[16] Although a receipt is not conclusive evidence, an exhaustive
review of the records of this case fails to disclose any other evidence sufficient and
strong enough to overturn the acknowledgment embodied in respondent's receipt as to
the amount it actually received from petitioner. Having failed to adduce sufficient
rebuttal evidence, petitioner is bound by the contents of the receipt issued by
respondent. The subject receipt remains as the primary or best evidence.[17]
The promissory note presented by petitioner cannot be considered as adequate
evidence to show the excessive placement fee. It must be emphasized that a
promissory note is a solemn acknowledgment of a debt and a formal commitment to
repay it on the date and under the conditions agreed upon by the borrower and the
lender. A person who signs such an instrument is bound to honor it as a legitimate
obligation duly assumed by him through the signature he affixes thereto as a token of
his good faith.[18] Moreover, as held by the CA, the fact that respondent is not a
lending company does not preclude it from extending a loan to petitioner for her
personal use. As for the deductions purportedly made by petitioner's foreign employer,
we reiterate the findings of the CA that "there is no single piece of document or receipt
showing that deductions have in fact been made, nor is there any proof that these
deductions from the salary formed part of the subject placement fee."[19]
At this point, we would like to emphasize the well-settled rule that the factual findings
of quasi-judicial agencies, like the POEA, which have acquired expertise because their
jurisdiction is confined to specific matters, are generally accorded not only respect, but
at times even finality if such findings are supported by substantial evidence.[20] While
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