Title
Supreme Court
Omanfil International Manpower Development Corp. vs. Mesina
Case
G.R. No. 217169
Decision Date
Nov 4, 2020
Overseas worker Mesina, diagnosed with heart disease, was repatriated without proper medical certification; SC ruled his dismissal illegal, citing work-related aggravation and lack of compliance with termination requirements.

Case Summary (G.R. No. 133385)

Antecedents and Employment Details

Rolando B. Mesina was employed by Omanfil International Manpower Development Corporation as an Expediter on an overseas assignment to Mohd Al-Zoabi Technical Projects Corporation in Dammam, Saudi Arabia. Mesina's employment commenced on May 4, 2005, under a contract specifying various terms, including a 24-month duration, a monthly salary of SR 4,000, and provisions for medical treatment in case of work-related illness or injury.

Medical Condition and Repatriation

After nine months in his role, Mesina experienced severe chest pains and was hospitalized twice in February 2006. Despite a diagnosis of heart disease, he was discharged in good condition. On February 20, 2006, following a request from MAZTPC, Mesina was repatriated to the Philippines due to his medical condition, allegedly against his will, although petitioners later claimed he opted for repatriation to seek treatment at home.

Claims for Medical Expenses and Illegal Dismissal

Upon returning to the Philippines, Mesina sought reimbursement for medical expenses totaling PHP 500,000, asserting that petitioners denied his claims based on their interpretation of the employment contract, which limited medical benefits to the duration of employment. Mesina subsequently filed a case for illegal dismissal, seeking damages and reimbursement.

Ruling of the Labor Arbiter

The Labor Arbiter dismissed Mesina's claim of illegal dismissal following a December 21, 2007, decision, finding that while no illegal dismissal occurred, he was entitled to separation pay. The Arbiter concluded that Mesina's repatriation fell under an authorized cause within the terms of his employment contract.

Ruling of the National Labor Relations Commission (NLRC)

Mesina appealed the Labor Arbiter's decision to the NLRC, which upheld the dismissal of his illegal dismissal claim in its May 29, 2009 ruling, stating that the repatriation was justified by his medical condition according to the employment contract's terms. The NLRC emphasized that the illness provided an authorized cause for employment termination.

Ruling of the Court of Appeals

Dissatisfied with the NLRC's findings, Mesina filed a petition for certiorari with the Court of Appeals, which, in its March 11, 2014 decision, ruled that petitioners illegally dismissed Mesina. The CA concluded that there was insufficient evidence that his condition was prolonged or permanent, negating the justification for repatriation and termination.

Petitioners’ Motion for Reconsideration and Arguments

Petitioners' motion for reconsideration was denied in February 2015, leading to their petition before the Supreme Court. They argued the CA erred by not recognizing the absence of a required medical certification which would validate termination due to disease.

Supreme Court's Ruling

The Supreme Court upheld the CA’s decision, affirming that petitioners failed t

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