G.R. No. 119080 - Singa Ship Management Philippines, Inc. vs. National Labor Relations Commission

On May 22, 1990, respondent Mario Sangil signed an employment contract with petitioner SINGA Ship Management Phils., Inc. on behalf of its foreign principal, Royal Cruise Line of Piraeus, Greece.
The contract provided for twelve (12) months of employment aboard the passenger cruise vessel Crown Odyssey as a utility man/assistant steward.
His compensation was set at a basic monthly salary of US $50.00, in addition to tips.
On June 2, 1990, he departed the Philippines to join the vessel in accordance with the contract.

While onboard the Crown Odyssey, Mario Sangil encountered a hostile environment characterized by animosity between the Filipino crew and the Greek crew.
On July 20, 1990, at approximately 9:00 a.m. in Stockholm, Sweden, a heated altercation occurred between respondent Sangil and Greek deck steward Athanasius “Thanasi” Zakkas.

During the dispute, Zakkas pushed Sangil, causing him to fall and hit his head against the steel molding of a door.
As a result of the fall, Sangil sustained a head injury—a scalp laceration that necessitated stitches by the ship’s doctor.

The night before the incident, Zakkas threatened to pour hot coffee on Sangil’s head.
Earlier on the day of the incident, while Sangil was performing his duties (washing the alleyway of the crew deck), Zakkas had verbally abused him by cursing and calling him derogatory names, including “malaca” (son of a prostitute).

Sangil reported the incident to the Philippine Embassy in Stockholm, where Consul Eduardo V. Aro assisted him.
He subsequently informed Ship Captain Yannis Katraz of his intention to leave the vessel due to the head injury and fear of further trouble.
Concerned for his well-being, Sangil was taken to Sabbatsberg Hospital in Stockholm for observation from July 20 to 21, 1990.

After his brief hospitalization, Sangil executed an affidavit before Consul Aro detailing the abusive treatment he received, including continued ridicule and threats from his Greek crewmates.
On July 24, 1990, Sangil was repatriated to the Philippines.

On March 6, 1991, respondent Sangil filed a complaint before the Philippine Overseas Employment Agency (POEA) alleging illegal dismissal and seeking:

The POEA dismissed his complaint on March 20, 1992, ruling that he had “voluntarily signed off from the vessel.”

On December 14, 1994, the National Labor Relations Commission (NLRC) reversed the POEA decision:

The NLRC ordered petitioners SINGA and Royal to pay respondent Sangil US $500.00 representing his salary for ten (10) months of the unexpired contract.
Additionally, the NLRC mandated payment of attorney’s fees amounting to 10% of the US $500.00.

Claims for overtime pay and tips were dismissed for lack of supporting evidence.
A motion for reconsideration was filed on January 20, 1995 by petitioners but was denied on February 6, 1995.

Distorting the evidence.
Overextending legal presumptions and disregarding the doctrine of res ipsa loquitur.

The incident was entirely respondent Sangil’s own doing.
His leaving the ship was voluntary.
Sangil’s reaction and claim of injury were a result of his own actions (i.e., leaping in a rage leading to an accidental fall due to water on the floor).

The ship’s Logbook Abstract indicated that Sangil was “pushed and fell down and suffered scalp trauma.”
Police investigation took away Athanasius Zakkas for questioning, supporting the finding that Sangil was not the aggressor.
Evidence showed that Sangil had previously complained about the abusive behavior of the Greeks and that the captain had failed to provide a safe working environment.

Whether respondent Sangil’s departure from the Crown Odyssey constituted a voluntary quitting or a case of constructive (illegal) dismissal.

Did the hostile and unsafe working conditions, including the physical altercation and the captain’s inaction, force Sangil to resign?
Is there sufficient evidence to establish that Sangil’s decision to leave was driven by a well-founded fear for his life?

Whether the NLRC correctly assessed the evidence, particularly the entries in the ship’s Logbook and respondent’s affidavit, in affirming the claim for constructive dismissal.
Whether petitioners’ arguments that the incident was solely caused by Sangil’s own actions overcome clear evidence of employer negligence in safety and supervision.