Case Digest (G.R. No. 114714) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 114714 decided on April 21, 1995, before the Supreme Court First Division sitting in Manila, The Conference of Maritime Manning Agencies, Inc. (an association of licensed Filipino manning agencies) and twenty co-petitioners, all licensed maritime manning agencies recruiting Filipino seafarers for foreign shipowners, filed a petition for certiorari under Rule 65 of the Rules of Court against the Philippine Overseas Employment Administration (POEA), Administrator Hon. Nieves Confessor, and Administrator Hon. Felicisimo Joson, seeking to annul Governing Board Resolution No. 01, series of 1994, and Memorandum Circular No. 05, series of 1994. The challenged Resolution, approved on January 14, 1994 and effective sixty days after publication, increased minimum death compensation in the POEA Standard Employment Contract for seafarers to US$50,000 plus US$7,000 per child (up to four), with war risk double indemnity, and adjusted Appendix rates. The Circular, issued January Case Digest (G.R. No. 114714) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioners: The Conference of Maritime Manning Agencies, Inc., Alster International Shipping, Inc., Creamship Management, Inc., El Grande Shipping Corp., Eastgate (Int’l.) Maritime Agencies, Inc., Filipinas Kalayaan Overseas Shipping Corp., Interworld Shipping Corp., JZEL Company, Inc., Laine Shipping Agency Corp., Mariners Services, Corp., Maritime Services & Mgt., Inc., Mid Ocean (Phils.) Marine Agency, Ocean East Agency Corp., Pasia-Phil. Group, Inc., Phil. Marine Consultant Inc., Seastar Marine Services, Inc., TSM Shipping (Phils.) Inc., Trans-Med (Manila) Corporation (all licensed manning agencies).
- Respondents: Philippine Overseas Employment Administration (POEA), Hon. Nieves Confessor, and Hon. Felicisimo Joson.
- POEA Governing Board Resolution No. 01, series of 1994 (14 January 1994)
- Amended Part II, Section C (Compensation and Benefits) of the POEA Standard Employment Contract for Seafarers:
- Death benefit of US$50,000 in Philippine peso equivalent; additional US$7,000 per child (max 4).
- Doubling of death benefit for warzone casualties; employer to secure warzone insurance.
- Adjusted maximum rate in Appendix I-A to US$50,000 for all ranks.
- Effectivity sixty (60) days after publication; application to causes arising after effectivity.
- POEA Memorandum Circular No. 05, series of 1994 (19 January 1994)
- Implemented Governing Board Resolution No. 01 effective 20 March 1994.
- Clarified applicability to Filipino seafarers already on board, for causes arising after effectivity date.
- Tripartite Technical Working Group
- Convened 7 January 1994 to review compensation and benefits.
- Membership included POEA directors, seafarer employers’ and manning agencies’ representatives, and labor union representatives.
- Proceedings
- Petitioners filed petition for certiorari and prohibition before the Supreme Court challenging POEA Resolution and Circular.
- Respondents filed comments, arguing valid exercise of rule-making power, substantial representation by Technical Working Group, and proper consultations.
- Petitioners and respondents submitted memoranda; case set for resolution.
Issues:
- Whether the POEA has the power to fix and promulgate death and workmen’s compensation rates for Filipino seamen.
- Whether the POEA violated standards for exercising its rule-making authority.
- Whether the Resolution and Circular are unconstitutional under the Equal Protection and Contract Clauses of the Constitution.
- Whether the absence of a statutorily-mandated private sector representative on the POEA Governing Board invalidates its acts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)