Case Summary (G.R. No. 249195)
Background of the Case
On July 15, 2015, Alenaje lodged a complaint for illegal dismissal against his employers. He asserted that on April 14, 2015, he was employed as a steward under a six-month contract with a monthly salary of USD 644.00. Throughout his employment, he alleged he faced excessive workloads and was pressured to carry out tasks beyond his responsibilities, culminating in a confrontation with Chief Mate Kucharz and subsequent allegations of insubordination. His complaint included claims for unpaid contract portions, damages, and attorney's fees.
Job Responsibilities and Incident Leading to Resignation
Alenaje was the sole steward on the vessel M/V CPO New York and contended that he was required to work extremely long hours, which he claimed affected his ability to perform his duties adequately. On April 17, 2015, he was instructed to carry out an unusual task—stripping and waxing the navigational bridge floor—by Chief Mate Kucharz. Alenaje stated this was not part of his job description and requested to perform the task later in the day, a request that was met with accusations of insubordination.
The Show Cause Notice and Subsequent Developments
Following the incident, Alenaje received a Show Cause Notice on April 18, 2015, for his alleged insubordination. A hearing was conducted where he explained his position, asserting he had not outright refused the order. Nevertheless, he was issued a Notice of Formal Warning, which further contributed to his sense of harassment, prompting his resignation on April 21, 2015.
Respondents’ Position
The respondents contended that Alenaje’s resignation was voluntary and not induced by any constructive dismissal. They argued that the tasks assigned were lawful commands and that prior to his resignation, he had been warned regarding his insubordination. They also highlighted that a disciplinary action for insubordination was properly documented and followed appropriate procedures.
Proceedings Before the Labor Arbiter (LA)
The Labor Arbiter initially found in favor of Alenaje, ruling that he had been constructively dismissed due to being assigned tasks outside his normal duties without adequate remedy from the respondents. The LA determined that the respondents had breached the employment contract and issued an order for them to pay Alenaje damages and the remaining salary.
Ruling of the National Labor Relations Commission (NLRC)
The respondents appealed the LA's decision to the NLRC, which reversed the finding, stating that Alenaje's resignation was voluntary and that he failed to prove constructive dismissal. The NLRC emphasized that the duties assigned to him did not constitute a valid basis for resignation, confirming that he did not sufficiently demonstrate how his employment conditions became unbearable.
Decision of the Court of Appeals (CA)
Alenaje then elevated the case to the CA, which upheld the decision of the NLRC, agreeing that the evidence supported the conclusion that Alenaje had voluntarily resigned. The CA noted that there was a lack of substantial evidence proving that Alenaje's
...continue readingCase Syllabus (G.R. No. 249195)
Overview
- The case revolves around a petition for review on certiorari filed by Rommel S. Alenaje against C.F. Sharp Crew Management, Inc., Reederei Claus-Peter Offen (GMBH & CO.), and Roberto B. Davantes.
- The petition challenges decisions made by the National Labor Relations Commission (NLRC) and the Court of Appeals (CA) regarding allegations of illegal dismissal.
Antecedents
- On July 15, 2015, Alenaje lodged a complaint against the respondents for illegal dismissal, unexpired contract payment, damages, and attorney's fees.
- He had worked as a seaman for 18 years and entered into a six-month employment contract on April 13, 2015, with a monthly salary of US$644.00.
- Upon boarding the vessel M/V CPO New York, he was the sole steward and had to perform additional duties, including acting as a mess man for the crew.
- On April 17, 2015, he was instructed by Chief Mate Kucharz to strip and wax the navigational bridge floor, a task he contended was not within his job description.
- Alenaje expressed his inability to perform the task immediately due to his responsibilities related to meal preparation, which led to accusations of insubordination.
Incident and Resignation
- Following the incident, Alenaje received a Show Cause Notice and a Notice of Formal Warning for insubordination.
- On April 21, 2015, feeling harassed, he tendered his resignation, which was accepted via email by the Senior Perso