G.R. No. 84672 - Imperial Victory Shipping Agency vs. National Labor Relations Commission

Tomas Fanega, Sr. filed a claim for the death benefits of his son, Tomas Fanega, Jr., who was employed as a seaman by a Greek company through petitioner Imperial Victory Shipping Agency.
Tomas Fanega, Jr. was hired through Christiaco Compania de Navera and was assigned to M/V Rhodian Sailor, which sank in Taiwan on December 26, 1982, leading to his presumed death along with 21 other Filipino crew members.

During the proceedings before the National Seaman Board, the P&I Club (the insurer for the shipowner) offered to pay the death benefit in the amount of P52,500 as provided under the POEA Standard Employment Contract.
Private respondent (Tomas Fanega, Sr.) refused the offer based on advice from his lawyer, who suggested that he could potentially recover a larger sum through a foreign suit.
A claim was subsequently filed abroad; however, the collection of the insurance benefits became impossible due to the alleged bankruptcy of the insurer.

The private respondent filed his case with the Philippine Overseas Employment Administration (POEA) on December 16, 1985, within the statutory three-year period from the date of the seaman’s death.
Hearings conducted from January 20, 1986, to March 4, 1987, revealed testimony from counsel (Atty. Joseph Capuyan) regarding the handling of the case, including the initial claim abroad and the subsequent change of mind by the private respondent.
The POEA initially ruled against the private respondent on the ground that he could not sue in two fora simultaneously for the same cause of action and also invoked the doctrine of laches due to the pending foreign case.

The National Labor Relations Commission (NLRC) first issued a decision on December 11, 1987, affirming the POEA’s stance by dismissing the claim on the basis of filing a double suit and laches.
On motion for reconsideration, the NLRC reversed its earlier decision on May 30, 1988, setting aside the previous dismissal and ordering petitioner Imperial Victory Shipping Agency, along with Christiaco Compania de Navera, to pay the death compensation benefits amounting to P130,000 plus attorney's fees.
The reversal was based on findings that the failure to collect the insurance benefit from abroad did not bar recovery under the POEA Standard Employment Contract.

Petitioner argued that the NLRC committed grave abuse of discretion by reversing its original dismissal.
It contended that the December 11, 1987, decision was final and executory due to the timely filing of the motion for reconsideration, citing legal technicalities regarding the computation of the appeal period when the 10th day fell on a Sunday or legal holiday.
Petitioner further invoked the doctrine of laches, claiming that liability should be avoided since its manning agreement with its principal had already been terminated long before the incident, and that enforcing the claim would result in inequitable double recovery.

Whether the NLRC committed grave abuse of discretion in reversing its initial decision dismissing the claim for lack of merit.
Whether the filing of the motion for reconsideration was timely given that the 10th day fell on a Sunday or legal holiday, thus affecting the finality of the December 11, 1987, decision.
Whether the doctrine of laches can bar the recovery of death benefits even though the complaint was filed within the three-year prescriptive period.
Whether the principle against double recovery—suing in two fora for the same cause of action—applies in this case, especially considering the pendency and subsequent status of the foreign suit.
Whether the petitioner, as the manning agent (or former agent) responsible for the seaman’s employment, remains jointly and severally liable for recovery under the POEA Standard Employment Contract notwithstanding any change in its contractual status.