Facts:

• In June 2004, Angelito L. Caseñas was hired by APQ Shipmanagement Co., Ltd. on behalf of APQ Crew Management USA, Inc. as Chief Mate for the vessel MV Perseverance.
• His contract was for eight months, from June 16, 2004, to February 16, 2005, with a basic monthly salary of US$840.00 and overtime pay of US$329.00.
• Caseñas left Manila on June 16, 2004, to join MV Perseverance in Miami, Florida.
• Due to incomplete documents, the vessel couldn't leave port, and Caseñas was transferred to MV HAITIEN PRIDE in Haiti, which also couldn't leave port due to incomplete documents.
• The crew, including Caseñas, was left without food and water, had to fish for food, and was not paid their salaries.
• Caseñas experienced extreme stress and anxiety, and his employment was extended from eight to twenty-six months.
• In August 2006, he suffered from shortness of breath, headache, and chest pains, leading to a diagnosis of hypertension and ischemic heart disease.
• He was repatriated to the Philippines on August 30, 2006, and declared unfit for sea service.
• Caseñas demanded payment of permanent total disability benefits, sickness allowance, and unpaid salaries, but APQ refused, leading him to file a complaint.
• APQ contended that Caseñas refused repatriation upon contract expiration and that they were not liable for claims after the contract expired.
• The Labor Arbiter (LA) dismissed Caseñas' complaint, ruling that the employment contract was not extended by mutual consent.
• The National Labor Relations Commission (NLRC) initially reversed the LA decision, finding the contract extended and the illness compensable.
• Upon reconsideration, the NLRC sided with the LA, stating that Caseñas failed to prove mutual consent for the extension.
• The Court of Appeals (CA) later nullified the NLRC's final decision and reinstated the earlier NLRC ruling, stating that the employment contract subsisted until Caseñas' repatriation.

Issue:

• (Unlock)

Ruling:

1. Yes, the Supreme Court ruled that the employment contract of Angelito L. Caseñas was extended with the implied consent of APQ/Crew Management.
2. Yes, Caseñas is entitl...(Unlock)

Ratio:

• The Supreme Court emphasized that employment contracts of seafarers are regulated and must incorporate the POEA Standard Employment Contract (POEA-SEC).
• The Court noted that Caseñas did not sign off from the vessel nor arrive at the point of hire upon the contr...continue reading