Philippine Transmarine Carriers v. Legaspi
REITERATIONFacts
The Antecedents: Respondent Leandro Legaspi was employed as a Utility Pastry on board the vessel "Azamara Journey" by petitioner Philippine Transmarine Carriers, Inc. His employment was governed by a Collective Bargaining Agreement (CBA) stipulating a maximum disability compensation of US$60,000.00. While at sea, respondent suffered a "Cardiac Arrest S/P ICD Insertation." Upon repatriation, the company-designated physician assessed his condition as Disability Grade 2. Dissatisfied, respondent filed a complaint for full and permanent disability compensation against petitioner. Procedural History: The Labor Arbiter (LA) ruled in favor of respondent, awarding US$80,000.00 for permanent disability compensation, US$1,320.00 for sick wages, and attorney's fees, based on the ITF Cruise Ship Model Agreement rather than the CBA. Petitioner appealed to the National Labor Relations Commission (NLRC), which affirmed the LA's decision. After the NLRC denied petitioner's motion for reconsideration and an entry of judgment was issued, petitioner paid respondent US$81,320.00 under an undertaking for its return should a petition for certiorari be granted. Petitioner subsequently filed a petition for certiorari with the Court of Appeals (CA). The LA issued a writ of execution, and petitioner paid additional amounts for attorney's fees and execution fees. The CA, unaware of the NLRC's entry of judgment and the prior payment, partially granted the certiorari petition, reducing the award to US$60,000.00 based on the CBA. Petitioner then sought to amend the CA's dispositive portion to recover the excess payment, but the CA denied this, deeming the petition moot and academic due to the prior satisfaction of the judgment. The Petition: Petitioner seeks review on certiorari under Rule 45 of the Rules of Court, assailing the CA's resolutions that denied its motion to amend the dispositive portion. Petitioner argues that its petition for certiorari was timely filed within the 60-day reglementary period, thus the NLRC resolutions had not attained finality and the case was not moot. Petitioner also contends that the Receipt of Judgment Award with Undertaking, which stipulated the return of payment if the certiorari petition was granted, made the case distinct from precedents where satisfaction of judgment rendered the petition moot. Petitioner asserts that the CA erred in applying Career Philippines Ship Management v. Geronimo Madjus and should have instead applied Leonis Navigation Co., Inc. v. Villamater, which allows for review of executed decisions under Rule 65. Petitioner seeks the return of the excess payment of US$29,452.00.
Issue(s)
Whether the Court of Appeals erred in ruling that petitioner is estopped from collecting the excess payment despite the signed Receipt of Judgment Award with Undertaking, and whether the petition for certiorari was rendered moot by the satisfaction of the judgment award. Whether the Court of Appeals erred in invoking the ruling of Career Philippines v. Madjus, and whether the respondent should return the excess payment.
Ruling
The petition is GRANTED. The Court of Appeals Resolutions dated January 5, 2012, and July 20, 2012, are REVERSED and SET ASIDE. Respondent Leandro Legaspi is ORDERED to return the excess amount of payment in the sum of US$29,452.00 to petitioner Philippine Transmarine Carriers, Inc. The amount shall earn interest at the rate of 12% per annum from the finality of this judgment.
Ratio Decidendi
On the issue of estoppel and mootness: The Court held that the petition for certiorari was not rendered moot by the satisfaction of the judgment award because the petition was filed within the 60-day period allowed under Rule 65. The CA could still review the NLRC's decision if the NLRC committed grave abuse of discretion. The satisfaction of the award does not automatically render the petition moot if there is an undertaking for its return. The Court found that the Receipt of Judgment Award with Undertaking was a fair and binding agreement. On the applicability of Career Philippines v. Madjus and the return of excess payment: The Court distinguished the present case from Career Philippines, where the employer's conditional satisfaction of judgment was deemed an amicable settlement that prejudiced the employee. In contrast, the Receipt of Judgment Award with Undertaking in the present case was fair to both parties. Since the CA granted the petition for certiorari, the respondent was obliged to comply with the condition to return the excess amount. Allowing the respondent to retain the excess payment would result in unjust enrichment. This situation is consistent with Section 14, Rule XI of the 2011 NLRC Rules of Procedure, which provides for restitution of executed awards when the judgment is reversed or annulled.
Main Doctrine
A petition for certiorari filed before the Court of Appeals is not rendered moot by the satisfaction of the judgment award, provided that the satisfaction was made subject to an undertaking for the return of the payment in case the petition is granted, as such an agreement preserves the parties' remedies and prevents unjust enrichment.