G.R. No. 209383 - Seacrest Maritime Management, Inc. vs. Picar, Jr.

Respondent Mauricio G. Picar, Jr. was employed as Chief Cook by petitioner Sealion Shipping Limited (a United Kingdom company) through its local manning agent, Seacrest Maritime Management, Inc.
Picar’s service spanned several contracts from April 2005 until his last fixed-duration employment in 2010 aboard the vessel aMV Toisa Paladin, with the last contract commencing on September 5, 2010, at a basic salary of US$630.00 exclusive of overtime and benefits.

On September 24, 2010, while on board, Picar experienced high fever, chills, lumbar back pain, and difficulty with urination accompanied by hematuria.
He was first treated at the Maritime Medical Center PTE, Ltd in Singapore where he was diagnosed with a Urinary Tract Infection and Renal Calculus; after his initial check-up, he was sent back to the vessel but later readmitted on September 28, 2010, until his confinement ended on October 1, 2010.
Upon repatriation on October 2, 2010, further consultations in Manila with Dr. Natalio G. Alegre at St. Luke’s Medical Center and later with Dr. Efren R. Vicaldo confirmed the presence of a renal cyst, calyceal lithiasis, and essential hypertension—conditions deemed work-aggravated and ultimately leading to Picar being declared unfit to resume his seafaring duties.

Picar filed a complaint seeking permanent disability compensation, balance of sick wages, reimbursement of medical expenses, moral and exemplary damages, and attorney’s fees.
The Labor Arbiter (LA) rendered judgment on June 22, 2011, determining that Picar’s illness was work-related, and ordered petitioners to pay a comprehensive award that included permanent disability compensation (US$60,000.00), sick wages (US$1,890.00), moral damages (P200,000.00), exemplary damages (P200,000.00), and attorney’s fees (10% of the judgment award).
The National Labor Relations Commission (NLRC) affirmed the LA decision, ruling that Picar suffered from permanent total disability as defined by the relevant labor standards and jurisprudence.

After the NLRC’s affirmation, and with the filing of a motion for execution, the LA issued a Writ of Execution on July 3, 2012; petitioners complied by paying the judgment award, as evidenced by the Satisfaction of Judgment with Acknowledgment Receipt executed on August 13, 2012.
Petitioners elevated the issue to the Court of Appeals (CA) via a petition for certiorari challenging the NLRC decision, but the CA dismissed the petition on May 2, 2013, as moot and academic, relying on the premise that the payment of the judgment award amounted to an amicable settlement.
A subsequent motion for reconsideration was denied by the CA on September 9, 2013, leading to the filing of the present petition for review under Rule 45 of the Rules of Court.

Whether the Court of Appeals committed reversible error in dismissing the petition for certiorari on the ground of mootness and academic character despite the conditional nature of the satisfaction of the judgment award.

Petitioners argue that the payment of the judgment award under a duly issued writ of execution was made without prejudice to their pending recourse before higher courts.
They assert that the conditional nature of the Receipt of the Judgment Award with Undertaking provided an avenue for a reversal of the judgment, should the petition for certiorari be granted, since it obligated the respondent to return the payment if the certiorari succeeded.
Conversely, respondent Picar contends that the voluntary satisfaction of the judgment award conclusively rendered the petition moot, emphasizing that the payment was an acknowledgment of the merits and finality of the LA and NLRC decisions.