G.R. No. 211837 - The Real Bank , Inc. vs. Maningas

Petitioners: Skippers United Pacific, Inc. and Skippers Maritime Services, Inc., Ltd. (Skippers) — a local manning agency and its foreign principal.
Respondents: Nathaniel Doza, Napoleon De Gracia, Isidro L. Lata, and Charlie Aprosta — seafarers deployed to work on the vessel MV Wisdom Star.
The seafarers filed a consolidated labor complaint against Skippers claiming unpaid home allotment for December 1998, unpaid salary for the unexpired portion of their employment contracts, moral damages, exemplary damages, and attorney's fees.
Skippers counter-claimed for reimbursement of repatriation expenses for De Gracia, Aprosta, and Lata as well as for moral damages and attorney's fees.

De Gracia: 3rd Engineer; 10-month contract starting 17 July 1998; monthly salary US$800.
Lata: 4th Engineer; 12-month contract starting 17 April 1998; monthly salary US$600.
Aprosta: Third Officer; 12-month contract starting 17 April 1998; monthly salary US$600.
No contract submitted for Doza.
All contracts incorporated compliance with POEA Department Order No. 33 and Memorandum Circular No. 55 (series 1996).

The seafarers claimed Skippers failed to remit their home allotments for nearly five months.
Multiple complaints were relayed by ITF Inspector of the Romanian Seafarers Union to the ship’s management regarding outstanding remuneration and poor ship conditions.
Skippers admitted non-payment of December 1998 home allotment only.
On 28 January 1999, the seafarers were discharged and repatriated immediately.
The seafarers then filed a complaint for illegal dismissal.

Asserted that De Gracia and others voluntarily pre-terminated contracts due to dissatisfaction and demanded immediate repatriation.
Alleged De Gracia was found drunk and disorderly on board.
Sought to offset unpaid home allotments against repatriation expenses borne by them.
Cited POEA Memorandum Circular No. 55 Section 19(G) for seafarer liability for repatriation payments upon early contract termination.

Labor Arbiter dismissed seafarers’ claims due to lack of merit and also denied Skippers’ claims for reimbursement.
National Labor Relations Commission (NLRC) affirmed the decision.
Respondents filed petition for certiorari with the Court of Appeals (CA).
The CA reversed and held Skippers liable for unpaid home allotment pay for December 1998, three months’ salary for unexpired contracts, and attorney's fees.
The CA ruled no award for Doza due to lack of factual basis.

Whether the dismissal of the seafarers was illegal, considering the alleged voluntary pre-termination by the seafarers.
Whether Skippers is liable for unpaid home allotment pay for December 1998.
Whether respondent seafarers are entitled to salaries for the unexpired portions of their employment contracts.
Whether attorney’s fees should be awarded despite the denial of moral and exemplary damages.