G.R. No. 126029 - People vs. Sunga

Petitioner, Pablo A. Coyoca, began working for Seafarers Shipping, Inc. in 1974.
His last contract was for a period of ten months, effective October 17, 1989, as First Engineer aboard the M/V Ficus, with a monthly salary of U.S. $1,100.00.

On February 14, 1990, petitioner was discharged due to an illness he contracted while on board, which later resulted in a stroke causing permanent partial disability.
On March 13, 1990, he received P42,315.00 as medical/disability benefits and subsequently signed a Receipt and Release, thereby discharging the private respondent from all claims related to the illness.

Petitioner filed a complaint with the Philippine Overseas Employment Administration (POEA) for recovery of separation pay and incentive pay, invoking Articles 284 and 95 of the Labor Code.
The POEA dismissed the complaint on the ground that the signing of the Receipt and Release barred any further claims.

The National Labor Relations Commission (NLRC) affirmed the POEA’s decision on appeal, thereby dismissing the petitioner's claims for additional benefits.
Petitioner sought certiorari questioning the Resolution of the NLRC, which essentially upheld the dismissal of his claim.

He claimed that he did not waive his rights to separation pay and incentive pay when he signed the Receipt and Release.
He argued that:

He was illegally dismissed, as his discharge was due to illness, not a justified termination under law.
The Receipt and Release was executed without the assistance of counsel and was not approved by the POEA.
Due to his long service since 1974, he had assumed the status of a regular employee, which entitled him to separation pay.

Petitioner also cited the Worth Shipping Services, Inc. case to establish that crew members might acquire regular status warranting separation benefits.

Petitioner’s contract did not provide for separation benefits.
The POEA standard employment contract for Filipino seamen similarly does not include provisions for separation or termination pay, being governed primarily by the Rules and Regulations Governing Overseas Employment.
Under his contract, the compensation for permanent partial disability was the sole benefit promised.

The document explicitly released all claims against the private respondent, covering any liabilities related to the illness and subsequent disability.
Petitioner acknowledged understanding the terms of the receipt, even affirming in a later letter that he had fully comprehended the contents before signing, thereby confirming a final and complete settlement of his claims.

Whether the execution of the Receipt and Release bar any further claims for separation pay and incentive pay despite petitioner's assertions that he did not waive these rights.
Whether petitioner's discharge due to illness constitutes illegal dismissal, entitling him to additional benefits beyond the medical/disability compensation received.
Whether petitioner's long-term service (since 1974) qualifies him as a regular employee under the Labor Code, thus warranting payment of separation pay as provided under Article 284.
The applicability of Articles 284 and 95 of the Labor Code in the context of his employment as a seaman, given the terms of his employment contract and the governing Rules and Regulations for Filipino seamen.
Whether his claim may be compared and differentiated from previous cases, specifically the Worth Shipping Services, Inc. case, regarding the issue of regular status and employer liability.