Title
Supreme Court
Omanfil International Manpower Development Corp. vs. Mesina
Case
G.R. No. 217169
Decision Date
Nov 4, 2020
Overseas worker Mesina, diagnosed with heart disease, was repatriated without proper medical certification; SC ruled his dismissal illegal, citing work-related aggravation and lack of compliance with termination requirements.

Case Digest (G.R. No. 217169)
Expanded Legal Reasoning Model

Facts:

  • Background and Employment Terms
    • Petitioner Omanfil International Manpower Development Corporation hired respondent Rolando B. Mesina as an Expediter for an overseas assignment.
    • Mesina’s employment contract, effective May 4, 2005, provided the following:
      • A fixed employment duration of 24 months.
      • A monthly salary of SR 4,000.
      • Benefits including 30 days of annual leave after completion of 12 months of service.
      • Specific provisions for medical treatment in cases of accident or illness incurred during the project, with free medical treatment rendered only during the period of employment.
  • Deployment and Medical Incidents
    • Mesina was deployed to work at Al Khaji Joint Operations (AKJO) in Dammam, Saudi Arabia under the supervision of petitioner Mohd Al-Zoabi Technical Projects Corporation (MAZTPC).
    • Within his first nine months of employment, Mesina began experiencing chest pains:
      • In the first week of February 2006, he suffered severe chest pains and was admitted to a local hospital on February 11, 2006, where he was diagnosed with a heart condition but discharged as “in good condition.”
      • He was readmitted on February 18, 2006 due to recurring chest pains and discharged on February 19, 2006 with advice to undergo an Angiogram Test at a better-equipped hospital.
  • Repatriation and Dispute Over Medical Treatment
    • Petitioners’ version:
      • Contended that Mesina opted to return to the Philippines, seeking better medical care for his condition in the presence of his family.
      • Claimed that they had provided Mesina with an entry-reentry visa, thereby implying that his repatriation was voluntary, and he was expected to resume work post-recovery.
    • Mesina’s version:
      • Asserted that MAZTPC requested his immediate repatriation on February 20, 2006 due to his serious medical condition, effectively pre-terminating his employment.
      • He was repatriated on February 22, 2006.
    • In the first week of June 2006, upon reporting to Omanfil, Mesina sought reimbursement for P500,000.00 in medical and operative expenses, presenting, among others, a quotation from the Philippine Heart Center.
    • Petitioners denied his demands, relying on the contract provision that free medical treatment was available only during active employment, and maintained that his heart ailment was neither work-related nor subject to the extensive benefits claimed.
  • Procedural History and Lower Forum Decisions
    • Mesina filed a case for illegal dismissal, refund of hospitalization and medical expenses, damages, and attorney’s fees, contesting his termination.
    • Labor Arbiter Decision (December 21, 2007):
      • Dismissed Mesina’s claim for illegal dismissal on the ground of lack of merit.
      • Ordered petitioners to pay him separation pay amounting to SR 4,000.00.
    • National Labor Relations Commission (NLRC) Decisions:
      • In the May 29, 2009 Decision, the NLRC affirmed the Labor Arbiter’s ruling, holding that Mesina’s dismissal was based on a contractually authorized cause – namely that an employee is to be repatriated if his illness is prolonged or permanent.
      • A subsequent Motion for Reconsideration was filed by Mesina but was denied in the February 26, 2010 Resolution.
    • Court of Appeals (CA) Decisions:
      • In the March 11, 2014 Decision, the CA ruled that Mesina’s contract was pre-terminated without just or authorized cause, thereby deeming his dismissal illegal.
        • The CA found that petitioners failed to prove that his heart disease was prolonged or permanent as required by the contract and applicable law.
        • The decision ordered petitioners to pay full reimbursement of his placement fee and his salaries for the unexpired portion of his employment contract.
      • Petitioners’ Motion for Reconsideration of the CA Decision was denied on February 25, 2015.
  • Petition for Review and Supreme Court’s Analysis
    • Petitioner petitioned for review on certiorari under Rule 45 of the Rules of Court, contending that the CA erred in holding that Mesina was illegally dismissed due to the absence of a required medical certification under Section 8, Rule I of the Omnibus Rules Implementing the Labor Code.
    • The Supreme Court examined the contractual provision (Item 8) and the legal requirements for dismissal on the ground of disease, noting that:
      • For a valid dismissal on the ground of disease, there must be certification from a competent public authority that the disease cannot be cured within six months even with proper treatment.
      • There was no evidence or certification establishing that Mesina’s ischaemic heart disease was prolonged or permanent.
      • The absence of such certification meant that his repatriation did not satisfy the contractual or legal criteria for termination based on disease.
    • The Supreme Court also addressed petitioners’ contentions regarding the voluntary nature of repatriation and the alleged exclusion of a pre-existing heart condition, finding these arguments unpersuasive.

Issues:

  • Whether the dismissal of Mesina for his heart ailment was legally justified under the employment contract and applicable labor laws.
    • Specifically, whether petitioners complied with the strict procedural and substantive requirements—particularly the mandatory certification by a competent public health authority—when terminating employment on the ground of disease.
  • Whether Mesina’s repatriation to the Philippines constituted an illegal dismissal given the lack of evidence that his heart condition was prolonged or permanent.
    • Whether the repatriation was voluntary or orchestrated by petitioners, as claimed by Mesina.
  • Whether the petitioners’ argument—that Mesina’s repatriation was voluntary and that his congenital condition was aggravated by an unhealthy lifestyle—sufficiently justifies dismissal under the law and contract provisions.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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