Case Digest (G.R. No. 231748) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Richard Lawrence Daz Toliongco v. Court of Appeals, National Labor Relations Commission, and Anglo-Eastern Crew Management Philippines, Inc. et al. (G.R. No. 231748, July 08, 2020), Toliongco was hired on October 30, 2013 as a messman by Anglo-Eastern Crew on board the M/V Mineral Water under a seven-month contract. On June 27, 2014, while cleaning the galley, he was twice sexually harassed by Chief Officer Korolenko Oleksiy who demanded sexual acts. Toliongco resisted, reported the incidents in the ship’s logbook, and filed a complaint with the captain. Fearing for his safety after alleged death threats, he requested repatriation and signed off on July 12, 2014 in Manila. He later consulted private physicians who diagnosed him with Post-Traumatic Stress Disorder (PTSD) rendering him unfit for sea duty. On March 2, 2015, he filed before the Labor Arbiter a complaint for constructive dismissal, sexual harassment, and maltreatment with prayers for disability benefits, unexpired Case Digest (G.R. No. 231748) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and Incident
- On October 30, 2013, petitioner Richard Lawrence Daz Toliongco was hired by Anglo-Eastern Crew Management Philippines, Inc. as Messman on board M/V Mineral Water under a seven-month POEA-standard contract.
- On June 27, 2014, Chief Officer Korolenko Oleksiy twice forcibly attempted to engage Toliongco in sexual acts in his cabin. Toliongco resisted, fled, and reported the incidents to Able Seaman Paner, Chief Cook Eseo, and ultimately the Captain. The events were entered in the Deck Log Book.
- Fearing further harm and death threats, Toliongco requested repatriation and was sent home on July 12, 2014.
- Medical Findings and Procedural History
- Upon return, company doctors confirmed he was harassed; on November 24, 2014, Dr. Randy Dellosa diagnosed Toliongco with Post-Traumatic Stress Disorder (PTSD), confirmed by Dr. Li-Ann Lara-Orencia.
- Toliongco filed complaints with OWWA, NCMB, and, on March 2, 2015, a labor complaint for constructive dismissal, sexual harassment, maltreatment, disability benefits, unexpired salary, damages, and attorney’s fees.
- The Labor Arbiter found constructive dismissal, denied disability benefits for non-compliance with the 3-day medical-exam rule, but awarded unexpired salary, moral (₱20,000), exemplary (₱10,000) damages, and attorney’s fees (₱5,438.41). The NLRC modified awards, ordered unexpired salary in USD and ₱30,000 financial assistance, deleted moral/exemplary damages. The Court of Appeals affirmed; this Petition ensued.
Issues:
- Entitlement to Disability Benefits
- Is the three-day post-employment medical-exam and reportorial rule mandatory, and did Toliongco’s PTSD excuse non-compliance?
- Is Toliongco’s PTSD a work-related illness or work-aggravated under the POEA-SEC?
- Entitlement to Other Relief
- Is Toliongco entitled to moral and exemplary damages for sexual harassment and constructive dismissal?
- Is he entitled to attorney’s fees and salary for the unexpired portion of his contract?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)