Philippine International Shipping Corporation v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: This case originated from a claim filed by Brigido Samson against Philippine International Shipping Corporation (PISC) for disability compensation benefits and hospitalization expenses under his employment contract. Samson, employed as a Second Engineer, was repatriated due to illness after sustaining an injury while serving on PISC's vessel, the M/V "ASEAN KNOWLEDGE." 2. Procedural History: The National Seamen Board (NSB) initially ordered PISC to pay Samson US $3,800.00 in disability benefits and US $380.00 in attorney's fees. PISC appealed this decision to the National Labor Relations Commission (NLRC). During the appeal, PISC paid Samson P18,000.00, for which Samson executed a release document. The NLRC affirmed the NSB's decision. Subsequently, the NSB issued a writ of execution. The Sheriff reported that P18,000.00 had been paid, but refrained from collecting the balance pending the Board's decision. A hearing was held, and the NSB issued an order on June 17, 1982, deeming the P18,000.00 as partial payment and ordering an amended writ of execution for the remaining balance and attorney's fees. PISC's motion to quash this amended writ was denied, and their subsequent appeal to the NLRC was also dismissed. 3. The Petition: PISC filed a petition for certiorari with the Supreme Court, alleging that the NLRC erred in not quashing the amended writ of execution despite the release executed by Samson, and in recognizing a decision that ordered payment in dollars, violating law. The Supreme Court found no merit in the petition, holding that the award was not in violation of law as it allowed for payment in Philippine currency equivalent, and that the P18,000.00 payment did not constitute full satisfaction of the award due to Samson's circumstances at the time of signing the release and the finality of the NLRC's decision.
Issue(s)
Whether the respondent NLRC erred in not quashing the amended writ of execution despite the release executed by private respondent. Whether the respondent NLRC erred in recognizing a decision ordering payment in the dollar standard in violation of law.
Ruling
The petition is dismissed for lack of merit. The NLRC did not err in upholding the amended writ of execution and in affirming the decision ordering payment in dollars equivalent to Philippine currency.
Ratio Decidendi
On the issue of the release document and amended writ of execution: The Court held that the P18,000.00 paid by PISC to Samson did not constitute full satisfaction of the award. The private respondent's execution of the "Release" document was made under circumstances where he badly needed funds for his ongoing medical treatment, and he accepted the amount as partial payment. The law does not consider valid any agreement to receive less compensation than what a worker is entitled to recover, citing MRR Yard Crew Union versus Philippine National Railways. Furthermore, the fact that PISC did not move to dismiss its appeal after the alleged full satisfaction of the judgment negates the inference of a full settlement. The NLRC's finding of fact, supported by evidence and a hearing, that the payment was partial and not a waiver of the balance, is entitled to respect and should not be interfered with absent grave abuse of discretion, fraud, imposition, or mistake. On the issue of payment in the dollar standard: The Court found the petition untenable. While Republic Act No. 529 prohibits domestic obligations from being payable in foreign currency, this statute is not applicable here. The NSB decision, affirmed by the NLRC, expressly allowed payment of "its equivalent in Philippine Currency." Moreover, the fixing of the award in dollars was based on the parties' employment contract, which stipulated wages and benefits in dollars because Samson was engaged as an overseas seaman on PISC's foreign vessel. Therefore, there was no violation of R.A. No. 529.
Main Doctrine
A release document executed by an employee accepting a partial payment does not constitute a waiver of the remaining balance of the award, especially when the employee was in need of funds for ongoing medical treatment and the award was based on an employment contract stipulating wages in dollars for overseas service.