Case Summary (G.R. No. 223290)
Factual Background
Woodrow B. Camaso alleged that he entered into an employment contract dated July 15, 2014 to serve as Second Mate aboard the M/V Golfstraum for a six-month period with a basic monthly salary of US$1,178.00 and that he had been employed by respondents for almost five years prior and had boarded eight of their vessels. He developed a throat obstruction in November 2013 which progressed to lymph nodules and an initial diagnosis of tonsillar cancer while overseas, prompting medical repatriation and confirmatory diagnosis in the Philippines. Respondents initially paid for eight chemotherapy sessions, 35 cycles of radiation therapy, and sickwage allowances; thereafter respondents allegedly refused further medical payments and Camaso filed a complaint for disability benefits, sickwage allowance, reimbursement of medical and hospital expenses, and consequential damages before the National Labor Relations Commission, docketed as NLRC Case No. OFW (M) 07-09270-14.
Proceedings before the Labor Arbiter and the NLRC
The Labor Arbiter rendered a Decision dated November 28, 2014 in favor of Camaso, ordering respondents to pay total and permanent disability benefits in the amount of US$60,000.00 and ten percent of the total money claims as attorney's fees, while dismissing other monetary claims for lack of merit. On appeal, the NLRC promulgated a Decision dated March 19, 2015 reversing the Labor Arbiter and dismissing the complaint for lack of merit; the NLRC denied reconsideration in its Resolution dated April 28, 2015.
Petition before the Court of Appeals
Aggrieved by the NLRC rulings, Camaso filed a petition for certiorari before the Court of Appeals. In its Resolution dated August 12, 2015 the CA dismissed the petition for non-payment of the required docketing fees as mandated by Section 3, Rule 46 of the Rules of Court. Camaso moved for reconsideration asserting that a check representing payment of the docket fees was attached to the petition and that the omission on filing resulted from oversight by court personnel; in a Resolution dated March 4, 2016 the CA denied reconsideration, relying on the presumption of regularity of official acts and the Officer-in-Charge of the CA Receiving Section's statement that no cash, postal money order, or check was attached when the petition was originally filed.
Court of Appeals' Additional Grounds for Dismissal
The CA further held that even assuming a check had been attached to the petition, the check in question was a personal Metrobank check dated July 6, 2015 under the personal account of a certain Pedro L. Linsangan and that such personal checks are not a mode of payment sanctioned by the 2009 Internal Rules of the Court of Appeals, which allow payment only in cash, postal money order, certified, manager's or cashier's checks payable to the Court of Appeals, and therefore the attachment of the personal check did not cure the non-payment.
Issue Presented to the Supreme Court
The sole issue presented to the Supreme Court was whether the Court of Appeals correctly dismissed Camaso's petition for certiorari for nonpayment of docket fees.
Supreme Court Ruling
The Supreme Court found the petition meritorious and set aside the CA Resolutions dated August 12, 2015 and March 4, 2016. The Court remanded the case to the CA for resolution on the merits and directed the CA to order Camaso to pay the required docket fees within thirty days from notice of such order.
Legal Basis and Reasoning
The Court recognized that Section 3, Rule 46 of the Rules of Court requires payment of docket and other lawful fees and deposit for costs at the time of filing an original action before the Court of Appeals and that failure to comply is a sufficient ground for dismissal; however, the Court reiterated its established doctrine that the rule may be relaxed in appropriate circumstances. Citing Bibiana Farms & Mills, Inc. v. NLRC, La Salette College v. Pilotin, and other authorities, the Court explained that dismissal is discretionary and that the strict rule yields where justice and fair play require it. The Court reiterated two controlling criteria: that the fees be paid within a reasonable period and that there be no intention to defraud the government. Applying these principles, the Court found that the attachment of a Metrobank personal check to Camaso's petition, though not an authorized mode under Section 6, Rule VIII of the 2009 IRCA, demonstrated earnest effort and good faith to pay the docket fees and evidenced an absence of fraudulent intent. The Court further found that the Officer-in-Charge's assertion that no
...continue reading
Case Syllabus (G.R. No. 223290)
Parties and Procedural Posture
- Woodrow B. Camaso was the petitioner who filed a petition for certiorari before the Court of Appeals challenging the NLRC decision dismissing his complaint.
- TSM Shipping (Phils), Inc., Utkilen, and/or Jones Tulod were the respondents and former employers of the petitioner.
- The Labor Arbiter issued a decision dated November 28, 2014 awarding the petitioner total and permanent disability benefits and attorney’s fees.
- The National Labor Relations Commission (NLRC) reversed the Labor Arbiter in its Decision dated March 19, 2015 and denied reconsideration in a Resolution dated April 28, 2015.
- The petitioner filed a petition for certiorari before the Court of Appeals (CA), which issued Resolutions dated August 12, 2015 and March 4, 2016 dismissing the petition for non-payment of docket fees.
- The petitioner sought review by petition for certiorari before the Supreme Court challenging the CA’s dismissal.
Key Factual Allegations
- Camaso alleged that he entered a six-month employment contract dated July 15, 2014 with a basic monthly salary of US$1,178.00 to serve as second mate on the M/V "Golfstraum."
- The petitioner claimed prior service of almost five years with respondents and boarding of eight vessels before the subject contract.
- The petitioner developed throat obstruction and later lymph nodules, was initially diagnosed with tonsillar cancer abroad, and was medically repatriated to the Philippines on September 8, 2014.
- Medical tests at St. Luke’s Medical Center confirmed tonsillar cancer and the petitioner underwent eight chemotherapy sessions and thirty-five radiation therapy cycles.
- Respondents paid for the petitioner’s initial medical care and sickwage allowances but later refused further medical expense payments, prompting the petitioner to pay for continuing treatment.
- Believing his sickness to be work-related and respondents to be obligated, the petitioner filed for disability benefits, sickwage allowance, reimbursement of medical and hospital expenses, and consequential damages before the NLRC.
Lower Tribunal Findings
- The Labor Arbiter ruled in favor of the petitioner and awarded total and permanent disability benefits in the amount of US$60,000.00 plus ten percent (10%) of total money claims as attorney’s fees while dismissing other claims for lack of merit.
- The NLRC reversed the Labor Arbiter and dismissed the petitioner’s complaint for lack of merit in its March 19, 2015 Decision.
- The NLRC denied reconsideration of its Decision in a Resolution dated April 28, 2015, prompting the petitioner to elevate the case to the CA.
CA Proceedings and Rulings
- The CA issued a Resolution dated August 12, 2015 dismissing the petitioner’s certiorari petition for non-payment of the required docketing fees under Section 3, Rule 46 of the Rules of Court.
- The petitioner filed a Motion for Reconsideration arguing that a Metrobank personal check dated July 6, 2015 was attached to the petition as payment and that