Seacrest Maritime Management v. Picar
REITERATIONFacts
The Antecedents: Respondent Mauricio Picar, Jr. was employed as Chief Cook by petitioner Sealion Shipping Limited – United Kingdom, through its local manning agent Seacrest Maritime Management, Inc., from April 2005 until September 2010. During his last contract, Picar experienced severe symptoms including high fever, chilling, lumbar back pain, and difficulty urinating with blood. He was diagnosed with Urinary Tract Infection and Renal Calculus in Singapore and subsequently repatriated to Manila. Further medical examinations revealed a renal cyst on his right kidney, calyceal lithiasis, and a slightly enlarged prostate gland. Another physician diagnosed him with Right Renal Calculus and Essential Hypertension, deeming his illness work-aggravated and rendering him unfit to resume his seafarer duties. Picar subsequently filed a complaint for permanent disability compensation, sick wages, medical expenses, damages, and attorney's fees. Procedural History: The Labor Arbiter ruled in favor of Picar, ordering the petitioners to pay disability compensation, sick wages, moral and exemplary damages, and attorney's fees. The National Labor Relations Commission (NLRC) affirmed this decision in its entirety, holding that Picar's disability was permanent and total as he was unable to perform his job for over 120 days. Petitioners appealed to the Court of Appeals (CA). While the appeal was pending, Picar moved for the execution of the Labor Arbiter's decision, which was granted. Petitioners paid the judgment award, evidenced by a Satisfaction of Judgment dated August 13, 2012. The CA, however, dismissed the petition for certiorari, deeming it moot and academic due to the payment, citing Career Philippines Ship Management, Inc. v. Madjus. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek review under Rule 45 of the Rules of Court, assailing the CA's dismissal of their petition for certiorari. They argue that the payment of the judgment award was made under a writ of execution and without prejudice to their further recourse, thus not constituting a voluntary amicable settlement that would render the case moot. They contend that the CA erred in applying Career Philippines and should have resolved the petition on its merits. Petitioners assert that the payment was made in strict compliance with the NLRC Rules and that the settlement terms were fair, allowing for the return of funds if their petition were granted, as evidenced by a Receipt of Judgment Award with Undertaking. They seek the reversal of the CA's decision and the remand of the case for a decision on the merits.
Issue(s)
Whether the Court of Appeals (CA) erred in dismissing the Petition for Certiorari as moot and academic due to the petitioners' satisfaction of the judgment award during the pendency of the case.
Ruling
The petition is GRANTED. The May 2, 2013 Decision and the September 9, 2013 Resolution of the Court of Appeals are REVERSED and SET ASIDE. The case is REMANDED to the Court of Appeals for decision on the merits.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Court of Appeals (CA) committed a reversible error. Applying the pronouncements in 'Leonis Navigation v. Villamater' and 'Philippine Transmarine Carriers, Inc. v. Legaspi', the Court held that the satisfaction of a monetary award by an employer does not automatically render a petition for certiorari moot. In 'Leonis Navigation', the Court explained that a petition for certiorari under Rule 65 is an independent action that tests the jurisdiction or grave abuse of discretion of the National Labor Relations Commission (NLRC). Since petitioners filed their petition within the 60-day reglementary period, the subsequent payment of the award via a writ of execution does not strip the CA of its power to review the case. The Court distinguished the present case from 'Career Philippines Ship Management, Inc. v. Madjus', noting that in 'Career Philippines', the settlement was deemed 'amicable' because it was highly prejudicial to the employee who could no longer pursue other claims, whereas here, no such restrictive document was executed. In this case, the payment was made subject to a writ of execution and without prejudice to further recourse, which is fair to both parties as it allows the employer to seek restitution if the NLRC decision is eventually reversed. Thus, the petition was not rendered moot, and the case was remanded to the CA for a decision on the merits.
Main Doctrine
The satisfaction of a monetary award pursuant to a writ of execution, when done without prejudice and with stipulations fair to both parties, does not render a petition for certiorari moot and academic, as it preserves the right of the petitioner to pursue the certiorari proceedings.