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Migration Jurisprudence from the South › Philippines

Sto. Tomas v. Salac

Supreme Court of the Philippines · Philippines · 2012-11-13 · National court

Citation: G.R. No. 152642
Type of case: Constitutional and human rights
Outcome: Decided for the migrant side

Question

Is it constitutional to make the officers of a recruitment agency personally liable with the agency for workers’ claims?

What the court decided

Yes. Joint and several liability of corporate officers serves the state’s duty to protect overseas workers.

In plain language

Recruitment agencies argued it was unfair to make their directors personally pay workers’ claims. The Supreme Court said the rule is valid because it protects workers abroad.

Dalam bahasa sederhana

Agen perekrut berpendapat tidak adil membuat direkturnya membayar sendiri tuntutan pekerja. MA menyatakan aturan itu sah karena melindungi pekerja di luar negeri.

Pertanyaan: Apakah konstitusional menjadikan pengurus agen perekrut ikut bertanggung jawab pribadi atas tuntutan pekerja?

What happened afterwards

  • 2012-11-13: Liability rule upheld.

Sources

Open this decision in the interactive collection (compare, filter, Indonesian view, downloads).

Cite as: Institute for Migrant Rights (2026), Migration Jurisprudence from the South, version 0.1, https://theimr.org/court-decisions/d/ph-salac-2012/. This page summarizes a court decision for research and advocacy; it is not legal advice.

For researchers

This collection of decisions is built for empirical legal scholarship and socio-legal research on migration and the rights of migrant workers, as well as for advocacy.

The coded variables support statistical analysis in law: cross-national comparison, regression and event-history designs, and law and economics questions such as how recruitment fees, wage protection and limits on changing employer affect migrant workers. The data can be downloaded for replication.

Keywords: case law; jurisprudence; judicial decisions; comparative constitutional law; courts and migration; judicial behavior; litigation outcomes; refugee law; non-refoulement; citizenship and nationality; empirical legal studies; empirical legal scholarship; quantitative legal research; statistical analysis in law; law and economics; law and economics of migration; comparative law; socio-legal studies; legal pluralism; migration law; labor migration; migrant workers’ rights; human rights law; access to justice; Global South; Asia; Africa; Middle East; Latin America; Indonesia; open data; replication data.