Institute for Migrant Rights
Railway line at Cianjur station, c. 1890 · KITLV, CC BY 4.0

Migration Jurisprudence from the South › Philippines

Sameer Overseas Placement Agency v. Cabiles

Supreme Court of the Philippines · Philippines · 2014-08-05 · National court

Citation: G.R. No. 170139
Type of case: Private
Outcome: Decided for the migrant side

Question

After Serrano, Congress put the three-month cap back into the law. Is the re-enacted cap valid, and is the Philippine recruiter liable with the foreign employer?

What the court decided

The re-enacted cap is unconstitutional for the same reasons; the worker recovers salary for the unexpired term, and the recruitment agency is jointly liable with the foreign employer.

In plain language

A woman recruited in the Philippines for factory work in Taiwan was sent home early. The Supreme Court said the limit on her claim was still unfair, even though Congress had written it into the law again, and that the agency that recruited her must pay together with the employer.

Dalam bahasa sederhana

Seorang perempuan yang direkrut di Filipina untuk bekerja di pabrik di Taiwan dipulangkan lebih awal. MA menyatakan batas tuntutannya tetap tidak adil, walaupun Kongres sudah menuliskannya lagi dalam undang-undang, dan agen yang merekrutnya wajib membayar bersama majikan.

Pertanyaan: Setelah putusan Serrano, Kongres memasukkan kembali batas tiga bulan. Apakah batas itu sah, dan apakah agen perekrut di Filipina ikut bertanggung jawab bersama majikan di luar negeri?

What happened afterwards

  • 2014-08-05: Re-enacted cap struck down.
  • later: [Check whether the cap was removed from the statute.]

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/sameer-2014/. 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.

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