G.R. No. 81805 - Var-Orient Shipping Co., Inc. vs. Achacoso

Petitioners: Var-Orient Shipping Co., Inc. and Comninos Bros.
Respondents: Tomas D. Achacoso (POEA Administrator), and private respondents Edgar T. Bunyog, Vedasto Navarro, Eugenio Capalad, Raul Tumasis, Antonio Tanio-an, Celestino Cason, Danilo Manela, and Roberto Genesis, crew members of the vessel MPV "Silver Reefer."
The case arises from a complaint filed by petitioners with the Workers Assistance and Adjudication Office (WAAO) of the Philippine Overseas Employment Administration (POEA) against the private respondents for alleged violations of their contracts of employment.

The controversy involved the alleged violations of employment contracts by the private respondents, which purportedly caused damages resulting from the interdiction of the MPV "Silver Reefer" by the International Transport Workers Federation (ITF) at Kiel Canal, Germany, in March 1986.
After the filing of the complaint and joinder of issues, a hearing was held on March 4, 1987, where parties agreed to submit their position papers with the case then to be submitted for decision. Notably, only the private respondents submitted their position paper.
On September 9, 1987, the POEA Administrator rendered a decision dismissing the case against the private respondents with reprimands and ordering certain payments by the petitioners to the private respondents, including damages and attorney’s fees.
The dispositive orders included:

Dismissal of the case with warnings to private respondents to avoid repetition of offenses.
Exclusion of Ricardo Llanes from the case.
Reprimand and warning to the petitioners for non-compliance with POEA regulations.
Archiving of the case concerning other respondents with conditions for their inclusion in POEA's watchlist.
Payment by petitioners to private respondents for deducted allotments and attorney’s fees.
Payment to Edgar T. Bunyog of unserved salaries and attorney’s fees.

A copy of the decision was sent by registered mail to petitioners’ counsel, Atty. Francisco B. Figura, delivered to the receptionist, Marlyn Aquino, at the counsel’s address on September 21, 1987.
Atty. Figura denied receipt of the decision. Petitioners claimed they only learned of the decision when the writ of execution was served on November 20, 1987.
Petitioners, through new counsel, filed an urgent motion to recall the writ of execution arguing the decision had not been received and was hence not final and executory. This motion was denied by the public respondent on January 19, 1988.
Thereafter, the present petition for certiorari was filed by the petitioners on grounds of grave abuse of discretion and denial of due process.

Whether the POEA Administrator committed grave abuse of discretion in rendering the decision without a formal hearing, thereby denying the petitioners’ right to due process.
Whether the writ of execution issued was premature given that the petitioners allegedly did not receive a copy of the decision, rendering the decision not yet final and executory.
Whether the POEA Administrator gravely abused discretion in awarding damages to the private respondents, particularly in the amounts granted.
Whether the petitioners were properly given an opportunity to appeal or oppose the decisions and motions filed subsequent to the hearing.