We should add that much more than being stylish, a decision or resolution, especially
one resolving an appeal, should directly meet the issues for resolution; otherwise, the
appeal would be pointless. It is immaterial that the NLRC is a quasi-judicial body and
not a regular court. In any controversy, the appellant needs enlightenment on the issues
that befuddle him. Accordingly, assuming that petitioner should indeed be liable to
Macaraya, the NLRC should have discussed why Section 6, Rule I, Book III of the
POEA Rules should be applied notwithstanding the factual circumstances pointed out
by petitioner. As it was, petitioners theory that the case does not merit the application of
Section 6, Rule I, Book III of the POEA Rules was merely glossed over, such that it was
left with no other recourse but to file a motion for reconsideration and, after its denial,
the instant petition.
Worth stressing is the fact that petitioner does not question the validity of the monetary
awards to Macaraya. The basic issue here is: As between petitioner and MARS, who
should be held liable for such awards? This can only be resolved by interpreting Section
6, Rule I, Book III of the POEA Rules which states as follows:
SEC. 6. Transfer of Accreditation. The accreditation of a principal or a project may be
transferred to another agency provided that transfer shall not involve any diminution of
wages and benefits of workers.
The transferee agency in these instances shall comply with the requirements for
accreditation and shall assume full and complete responsibility for all contractual
obligations of the principals to its workers originally recruited and processed by the
former agency. Prior to the transfer of accreditation, the Administration shall notify the
previous agency and principal of such application.
A cursory reading of this provision lends the impression that an accreditation transferee
assumes the contractual responsibility of the transferor under all circumstances, without
qualification. We find, however, that a strict application of said proviso in this case may
result in a grave injustice to petitioner which became liable only when it stepped into the
shoes, as it were, of its predecessor after the issues had been met in the illegal
dismissal case filed against the latter, and after the POEA had failed to discharge its
duty of deciding the simple illegal dismissal case with dispatch.
The rule on transfer of accreditation was prescribed under the general policies of the
POEA to establish the environment conducive to the continued operations of legitimate,
responsible and professional private agencies and to afford protection to Filipino
workers and their families, promote their interests and safeguard their welfare.xiii[13] In
line with these policies, Book III of the same rules provides for the accreditation of a
principal or any foreign person, partnership or corporation hiring Filipino workers
through an agency.xiv[14] Principals may be accredited in this country only through
licensed local agencies.xv[15] A land-based principal shall be accredited to only one
agency but the POEA may grant accreditation to a second agent as may be deemed
necessary.xvi[16] In the same manner, the accreditation of a principal may be transferred
to another agency under the aforequoted Section 6, Rule I, Book III of the POEA Rules.