Title
Barros vs. National Labor Relations Commission
Case
G.R. No. 123901
Decision Date
Sep 22, 1999
A seaman who was repatriated before the end of his contract files a complaint for illegal dismissal, leading to a legal battle between the Philippine Overseas Employment Administration and the National Labor Relations Commission over the validity of the dismissal.
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Case Digest (G.R. No. 123901)

Facts:

  • Enrique A. Barros filed a complaint for illegal dismissal against TRANSORIENT Maritime Services, Inc., DAISHIN Shipping Co., Ltd., and Dominion Insurance Corporation.
  • Barros claimed that he was hired by DAISHIN through TRANSORIENT to work as First Assistant Engineer on board its vessel MV Monte Paloma for 12 months.
  • After 4 months of regular and efficient performance, Barros was ordered by his Japanese ship captain to go home at his own expense without any explanation.
  • Barros went to the office of TRANSORIENT to inquire about his repatriation but was assured of another employment.
  • The private respondents denied the illegal dismissal and claimed that Barros was repatriated upon his own request as reflected in his seaman's book.
  • The Philippine Overseas Employment Administration (POEA) ruled in favor of Barros, but the National Labor Relations Commission (NLRC) reversed the decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition and set aside the decision of the NLRC.
  • The Court reinstated and affirmed the decision of the POEA, declaring the dismissal of Barros as illegal and ordering the...(Unlock)

Ratio:

  • Factual findings and conclusions drawn by the NLRC are accorded great weight and respect, as long as they are supported by substantial evidence.
  • When the findings of the POEA and the NLRC contradict each other, the Court must examine the records and evidence to determine which findings are more conformable with the established facts.
  • There was no dispute that Barros was repatriated by the private respondents before the expiration of his contract of employment.
  • It was incumbent upon the private respondents to prove that Barros was not dismissed or that the dismissal was not illegal.
  • The entries in Barros' seaman's book, which the NLRC relied on to support the claim of voluntary repatriation, cannot be considered substantial evidence...continue reading

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