Haverton Shipping Ltd. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Alfredo Benitez was hired by OFSI Services, the local manning agent of Haverton Shipping, as a boatswain on the M.V. Gold Alisa for a one-year period with a monthly salary of US $485.00. While the vessel was berthed in Durban, South Africa, a fight occurred between Benitez and his shipmates, Maximo Espiritu and Arnel Candelaria. Espiritu suffered injuries to his fingers. Benitez was subsequently repatriated to the Philippines after serving only two and a half months of his contract. Procedural History: Benitez filed a complaint for illegal dismissal and unlawful termination of contract with the National Seamen's Board (NSB). The NSB, adopting Benitez's version, ruled that the ship's log book entry was hearsay. The National Labor Relations Commission (NLRC) affirmed the NSB decision, rejecting the affidavits of Candelaria and Espiritu as they were presented only on appeal. The Petition: Petitioners Haverton Shipping Ltd. and OFSI Services, Inc. filed a petition for certiorari with the Supreme Court, seeking to annul the NLRC decision, arguing that Benitez was terminated for just cause.
Issue(s)
Whether private respondent Benitez was terminated for just cause even before the expiration of his employment contract. Whether the entry in the ship's log book is admissible and binding evidence. Whether the affidavits of Candelaria and Espiritu, submitted on appeal, should have been considered.
Ruling
The Petition for certiorari is granted. The questioned Decisions of the NLRC are reversed, and the complaint is dismissed. The Temporary Restraining Order is made permanent.
Ratio Decidendi
On whether private respondent Benitez was terminated for just cause even before the expiration of his employment contract: The Court found that Benitez's actuations constituted serious misconduct in connection with his work, which is a just cause for termination under Article 283 of the Labor Code. The incident involved Benitez assaulting a shipmate with a knife, which seriously detracted from the safe and efficient working of the ship and the social well-being of others on board. His admission of wielding a knife and the injuries sustained by Espiritu, corroborated by the ship's log book entry and the master's findings, established just cause for his dismissal. Therefore, he is not entitled to salary for the unexpired portion of his contract. On whether the entry in the ship's log book is admissible and binding evidence: The Court held that public respondents overlooked the fact that under Philippine laws, the ship's captain is obligated to keep a log book where decisions are recorded. Even under the law of the vessel's registry, the log book is required by law. As an official record, entries made by a person in the performance of a duty required by law are prima facie evidence of the facts stated therein, pursuant to Section 38, Rule 130 of the Rules of Court. The genuineness of the log book entry was not in controversy, and it was found to be consistent with the injuries sustained by Espiritu. On whether the affidavits of Candelaria and Espiritu, submitted on appeal, should have been considered: The Court ruled that the NLRC should not have precluded itself from considering the affidavits of Candelaria and Espiritu, even though they were submitted on appeal. There was a plausible reason for the delay, as the affiants were out of the country until their contract expired. Article 221 of the Labor Code provides that rules of evidence prevailing in courts of law shall not be controlling, and every reasonable means to ascertain the facts shall be used without regard to technicalities. The affidavits corroborated Espiritu's narrative and the findings in the ship's log book.
Main Doctrine
The entry in a ship's log book, kept in compliance with legal obligations, is considered an official record and constitutes prima facie evidence of the facts stated therein. Such an entry, when corroborated by other evidence and not overcome by substantial proof to the contrary, can serve as a just cause for termination of employment.