Facts:

The case involves petitioners APQ Shipmanagement Co., Ltd. and APQ Crew Management USA, Inc., against respondent Angelito L. CaseAas. The dispute arises from CaseAas' employment as Chief Mate aboard the vessel MV Perseverance, starting June 16, 2004, with an initial contract of eight months ending on February 16, 2005, earning a basic monthly salary of $840.00 plus overtime pay. However, he was unable to depart as planned due to incomplete vessel documentation. As a result, CaseAas was transferred to another vessel, MV Haitien Pride, which was stationed in Haiti and also faced similar issues of unseaworthiness, where he and the crew remained without provisions for some time. During the course of his employment, including the purported extension of the contract to 26 months, he became ill, culminating in a diagnosis of Ischemic Heart Disease after being repatriated to the Philippines on August 30, 2006, due to health complications.

Upon his arrival, CaseAas underwent a post-e

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Facts:

Background of the Case

• Case Overview
• The case involves a petition for review on certiorari under Rule 45 of the Rules of Court by APQ Shipmanagement Co., Ltd. and APQ Crew Management USA, Inc. against Angelito L. CaseAas.
• The dispute arises from CaseAas’ claims for disability benefits, unpaid wages, sickness allowance, and reimbursement of medical expenses.
• Employment Details
• In June 2004, CaseAas was hired as Chief Mate by APQ (on behalf of its principal, Crew Management) to work on vessel MV Perseverance.
• His original contract lasted for eight (8) months from June 16, 2004, to February 16, 2005, with a basic monthly salary and additional overtime pay.

Alleged Contract Extension and Work Conditions

• Allegations by CaseAas
• Despite the original term, CaseAas claimed that his employment was extended to twenty-six (26) months, a fact he supported by submitting various documentary evidences (e.g., a Deck Logbook, a report by Mr. Steve Mastroropolous, and a letter from the president of APQ).
• He alleged that due to operational issues—such as MV Perseverance’s inability to leave port because of incomplete documents—he was transferred to MV Haitien Pride, where adequate provisions (food, water, salaries) were not provided and where he was left to fend for himself with his crewmates.
• While on board MV Haitien Pride, he suffered extreme stress, anxiety, and deteriorating health, eventually manifesting symptoms that led to diagnoses of Essential Hypertension, Ischemic Heart Disease, and related complications.
• Medical and Repatriation Issues
• In August 2006, after developing symptoms like shortness of breath, headache, and chest pains, he was examined and diagnosed by multiple doctors, including the company-designated physician.
• Despite his ill health and resultant inability to work beyond 120 days post-repatriation, APQ refused to provide further medical attention or pay the benefits he claimed.
• Employer’s Position and Communications
• APQ maintained that CaseAas’ contract expired as originally agreed and that there was no mutual consent regarding any extension.
• The petitioners argued that arrangements were already made for his repatriation as early as January 2005, substantiated by flight e-tickets and related correspondence.
• Nonetheless, subsequent communications (including letters and e-tickets sent by Crew Management) indicated that APQ was aware of, and did not object to, the continued service of CaseAas beyond the original contract period.

Proceedings in Lower Courts

• Labor Arbiter (LA) Decision
• On November 20, 2008, the Labor Arbiter dismissed CaseAas’ complaint, ruling that there was no legally valid extension of the contract and that the illness manifested outside the period of the original employment contract.
• NLRC Resolution and Subsequent Developments
• On June 22, 2009, the NLRC reversed the LA decision, ruling in favor of CaseAas upon finding that the employment contract was indeed extended and that his illness was compensable under Section 32-A, No. 20 of the POEA-SEC.
• However, on October 14, 2009, the NLRC reconsidered its earlier favorable resolution and set it aside based on the lack of documentary evidence of mutual consent for the extension.
• A subsequent resolution dated November 27, 2009, denied CaseAas’ motion for reconsideration.

Court of Appeals (CA) Decision

• Certiorari Petition Before the CA
• CaseAas filed a petition under Rule 65 before the CA, challenging the reconsideration of the NLRC decision.
• CA Ruling
• On January 24, 2011, the CA nullified and set aside the NLRC decision that reconsidered in favor of APQ, thereby reinstating the June 22, 2009 NLRC resolution awarding benefits to CaseAas.
• The CA rested its decision on the premise that the seafarer’s employment contract effectively continued due to the absence of a clear termination triggered by repatriation or sign-off, and based on the established guidelines under the POEA-SEC.
• Petitions for Reconsideration and Subsequent Denials
• Both petitioners (APQ and Crew Management) and CaseAas filed respective motions and comments regarding the CA decision.
• On June 1, 2011, the CA denied the motion for reconsideration, which ultimately led to the present petition for review.

Issue:

Existence and Validity of Contract Extension

• Whether the employment contract of CaseAas was validly extended beyond the original eight (8) month period with the proper, mutual consent of both CaseAas and the employers.
• Whether the documentary evidence and conduct of the parties implied consent to extend the contract.

Liability for Wages and Benefits

• Whether APQ and Crew Management should be held liable for the unpaid wages, sickness allowance, and disability benefits claimed by CaseAas during the extended period of employment.
• Whether the benefits for illness (manifesting as Essential Hypertension and Ischemic Heart Disease) contracted during the period of service fall within the compensable period under the POEA-SEC provisions.

Application of the POEA Standard Employment Contract (POEA-SEC)

• Whether the provisions in the POEA-SEC regarding contract duration, termination, and repatriation were properly applied to CaseAas’ employment scenario.
• How the absence of timely repatriation, proper sign-off, and other procedural requirements impacted the legal status of CaseAas’ employment contract.

Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

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