8/26/2020 E-Library - Information At Your Fingertips: Printer Friendly of moral damages is but appropriate. Consequently, the award of exemplary damages is necessary to deter future employers from committing the same acts. Additionally, petitioners are also entitled to the award of attorney's fees under Article 2208 of the Civil Code: ARTICLE. 2208. In the absence of stipulation, attorney's fees and expenses of litigation, other than judicial costs, cannot be recovered, except: (1) When exemplary damages are awarded; .... (5) Where the defendant acted in gross and evident bad faith in refusing to satisfy the plaintiffs plainly valid, just and demandable claim; .... (7) In actions for the recovery of wages of household helpers, laborers and skilled workers[.] The award of attorney's fees is proper because: (1) exemplary damages is also awarded; (2) respondents acted in gross bad faith in refusing to pay petitioners their hard-earned salaries in form of overtime premiums; and (3) this case is also a complaint for recovery of wages. In addition, we further sustain the Court of Appeals' ruling in having ordered the reimbursement of petitioners' placement fees. As they were terminated without just, valid, or authorized cause, petitioners are entitled to the full reimbursement of their placement fees with interest at 12% per annum in accordance with Section 7 of Republic Act No. 10022.[60] III In Serrano, this Court ruled that the clause "or for three (3) months for every year of the unexpired term, whichever is less" under Section 10[61] of the Migrant Workers and Overseas Filipinos Act is unconstitutional for violating the equal protection and substantive due process clauses. Later, however, this clause was kept when the law was amended by Republic Act No. 10022 in 2010. Section 7 of the new law mirrors the same clause: SECTION 7. Section 10 of Republic Act No. 8042, as amended, is hereby amended to read as follows: "SEC. 10. Money Claims. — Notwithstanding any provision of law to the contrary, the Labor Arbiters of the National Labor Relations Commission https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65230 10/19