For lack of better opportunities at the home front, workers are induced to leave for abroad with a promise of stable work and good pay. The ILO Private Employment Agencies Convention 181 (C181, 1997) 54 provides that private employment agencies shall not charge directly or indirectly, in whole or in part, any fees or cost to workers. The Philippines is not a signatory to the ILO Convention No. 181, but under Section 51 of Rule V of the Revised POEA Rules and Regulations Governing the Recruitment and Employment of Land based Overseas Filipino Workers of 2016, no placement fee may be charged against: (a) domestic workers; and (b) workers to be deployed to countries where the prevailing system, either by law, policy or practice do not allow, directly or indirectly, the charging and collection of recruitment/placement fees. Placement fees are also not allowed to be collected from OFW seafarers. Notwithstanding the foregoing however, private recruitment agencies in the Philippines and/or recruitment agency in the host country continue to charge recruitment fees from migrant workers, the domestic workers, in particular. Fees collected by private recruitment agencies for jobs abroad cover the cost of the recruitment itself, visa consultations, airfare and administrative costs. According to a study on Filipino domestic workers in Hong Kong by Varona (2013), majority 2/3 or (68%) had to take some kind of loan (from banks, financing agency, relatives or friends, or advanced by recruitment agency) to pay the recruitment costs, which can be substantial amounts.55 For marginal workers who do are unable to raise money from their own sources, they are often referred by recruitment agencies to financing companies for easy loans with exorbitant interests. Thus, even before deployment the worker is already deeply buried in debt and is required to issue post-dated checks as loan security, or pledge a portion of their expected wages for debt repayment. This happens through contract substitution, an illegal practice by placement agencies wherein workers are coerced into signing a non-state approved contract at the last minute. In the same survey by Varona, debt bondage was identified as a major concern, next only to violations of recruiters to the “no placement fee” policy for domestic workers. Although debt bondage per se was not one of the legal issues directly addressed in the cases decided by the Supreme Court in the period 2015-2019, there were several cases reviewed that indicated the existence of its practice. In the case of “Aldovino, et. al. vs. Gold and Green Manpower Management and Development Services, Inc.”,56 the findings of facts show that the workers applied for work with a local manning agency whose foreign principal is based in Taiwan. Eventually, they were hired with a fixed monthly salary and other entitlements. Before deployment, each worker was required to pay the amount of PhP72,000.00 as placement fee. Unable to 54 C181-Private Employment Agencies Convention 1997 (No. 181). International Labor Organization. https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_INSTRUMENT_ID: 312326 55 Rex Varona, “LICENSE TO EXPLOIT: A Report on the Recruitment Practices and Problems Experienced by Filipino Domestic Workers in Hong Kong,” (2013) https://idwfed.org/en/resources/license-to-exploit-a-report-on-recruitment-practices-and-problemsexperienced-by-filipino-migrant-domestic-workers-in-hong-kong/@@display-file/attachment_1 56 G. R. No. 200811, June 19, 2019 29