G.R. No. 57999 - Suzara vs. Benipayo

Petitioners: Resurreccion Suzara, Cesar Dimaandal, Angelito Mendoza, Antonio Tanedo, Amorsolo Cabrera, Dominador Santos, Isidro Bracia, Ramon de Belen, Ernesto Sabado, Martin Malabanan, Romeo Huerto, Vitaliano Pangue, and others — Filipino seamen employed on vessels of Magsaysay Lines, Inc.
Respondents: The Honorable Judge Alfredo L. Benipayo, Magsaysay Lines, Inc., the National Labor Relations Commission (NLRC), and the now Philippine Overseas Employment Administration (formerly National Seamen Board, NSB).

In 1977-1978, petitioners entered into separate NSB-approved employment contracts with Magsaysay Lines to serve aboard vessels for 12 months, with fixed salary, overtime pay, and allowances.
In April 1978, petitioners joined the M/V Grace River; on October 30, 1978, the vessel arrived at Vancouver, Canada.
At Vancouver, petitioners received additional wages totalling US$98,261.70, over and above their contracted salaries, according to rates prescribed by the International Transport Workers’ Federation (ITF).
On November 10, 1978, the vessel left Vancouver for Yokohama, Japan, where on December 14, 1978, the petitioners were ordered to disembark.

The NSB found petitioners guilty of breach of contract and ordered reimbursement of US$91,348.44 representing the excess wages, and suspended the petitioners from the NSB registry for three years.
The National Labor Relations Commission (NLRC) affirmed the NSB’s decision.
Due to petitioners’ refusal to return the overpayments, Magsaysay Lines filed estafa (fraud) charges against some petitioners, later consolidated before Judge Alfredo Benipayo.
Petitioners filed consolidated petitions for nullification of the NSB and NLRC decisions and dismissal of criminal estafa cases.

Petitioners claimed that no illegal acts or strikes were committed; the wage increases were valid and resulted from peaceful negotiations supported by the ITF.
Respondents alleged petitioners staged an illegal strike at Vancouver with ITF’s intervention, coercing the shipowner to pay wage differentials; the “special agreement” to pay increased wages was signed under duress;
NSB found petitioners’ conduct illegal and outside the lawful scope of labor negotiations.

Pay-Off Clearance Slips showed entries "DEMANDED ITF WAGES..." indicating petitioners requested and received higher wages through the ITF.
ITF’s intervention was at petitioners’ behest, applying pressure including interdiction threats to delay vessel departure for non-payment of increased rates.
The “special agreement” signed in Vancouver was compelled to avoid further delay.
Petitioners signed an “Agreement” in Nagoya, Japan, which included a clause inserted after signing ("amount(s) received and held by CREWMEMBERS in trust for SHIPOWNERS")—allegedly to invalidate their wage claim.

The NSB’s minimum basic wage at petitioners' contract time was US$130, below the International Labor Organization (ILO) minimum of US$187 set in 1976 but adopted by NSB only in 1979.
The ITF had been active internationally pressing for higher third-world seamen wages, particularly in Canada, without Filipino seamen requesting such intervention.
Despite allegations of illegal means, petitioners engaged in peaceful expression (e.g., placards) and continued to work.

Whether petitioner-seamen are entitled to wage differentials based on the ITF rates paid in Vancouver despite their NSB-approved contracts.
Whether the means employed by petitioners to obtain the additional wages constituted illegal acts such as an illegal strike or coercion.
Whether the NSB and NLRC had jurisdiction and valid basis to order reimbursement of wage differentials and impose suspension.
Whether the Philippine courts have jurisdiction over estafa charges against petitioners concerning acts allegedly committed outside the Philippines.
Whether the “special agreement” signed in Vancouver under pressure was valid and binding or obtained by duress or fraud.