Case Summary (G.R. No. 151908)
Facts of the Case
On July 24, 2012, Orlanes filed a complaint against Fairport, Stella Marris, and Navarro for non-payment of salary, travel allowances, and leave pay, totaling US$14,559.56. Orlanes contested that he was employed as the Master on the vessel M/V Orionis from August 4, 2009, to July 24, 2010, but did not receive his due compensation despite prior assurances from Fairport upon disembarkation on July 27, 2010. The respondents claimed that they were not liable for the amounts being demanded.
Respondents' Defense
Stella Marris argued that it should not be held accountable since it had executed an Affidavit of Assumption of Responsibility that covered obligations only from seafarers originally recruited by its predecessor, Global Gateway Crewing Services, Inc. (Global), which did not include Orlanes, who was initially hired by Skippers United Pacific, Inc. (Skippers). This argument brought into focus the complexities arising from transfers of manning agency responsibilities during Orlanes' employment.
Procedural History
Prior to the second complaint, Orlanes had filed a first complaint against Skippers, Fairport, and another individual. This was dismissed without prejudice by the LA, allowing Orlanes to refile as he saw fit. The NLRC later dismissed his appeal due to procedural flaws. Consequently, he initiated the second complaint against Fairport, Stella Marris, and Navarro.
Labor Arbiter's Ruling
On May 31, 2013, the LA ruled in favor of Orlanes, holding all manning agencies involved (Skippers, Global, and Stella Marris) solidarily liable with Fairport for the unpaid claims. The LA emphasized that the obligation of Skippers, as the original manning agency, extended even to parts of the contract handled under Global.
NLRC's Ruling
The NLRC reversed the LA's decision on October 30, 2013, ruling that the LA erred in attributing liability to Skippers and Global as they were not named as parties in the second complaint. It held that liability rests with Skippers, the original manning agent, and emphasized that the transfer of obligations through affidavits was not applicable to Orlanes since his contract was initially with Skippers.
Court of Appeals' Ruling
The CA, in its decision dated September 27, 2018, concurred with the NLRC, determining that Skippers should be held liable due to its joint and solidary liability with Fairport under the relevant laws. The CA dismissed the petition for certiorari from Orlanes after finding that the NLRC acted within its jurisdiction and authority.
The Current Issue
The primary issue for the Supreme Court was whether the CA and the NLRC erred in dismissing Orlanes' monetary claims against the respondents.
Supreme Court's Ruling
The Court ruled partly in favor of Orlanes, reiterating that under the relevant provisions of the Philippine Overseas Employment Administration (POEA) Rules and the Migra
...continue readingCase Syllabus (G.R. No. 151908)
Case Overview
- Case Reference: G.R. No. 247702
- Date of Decision: June 14, 2021
- Petitioner: Antonio D. Orlanes
- Respondents: Stella Marris Shipmanagement, Inc., Fairport Shipping Co., Ltd., and/or Danilo Navarro
- Legal Action: Petition for review on certiorari against the Decision dated September 27, 2018, and Resolution dated March 1, 2019, both from the Court of Appeals.
Background of the Case
- On July 24, 2012, Orlanes filed a second complaint before the Labor Arbiter for non-payment of salary, travel allowance, leave pay, and damages against Fairport, Stella Marris, and Navarro.
- Employment Details: Orlanes was employed as Master on the vessel M/V Orionis from August 4, 2009, to July 24, 2010, with an unpaid salary totaling US$14,559.56.
- Orlanes claimed he was assured payment upon disembarkation but did not receive any payment, prompting his complaint.
Respondents' Defense
- Stella Marris contended it should not be liable for Orlanes' claims, asserting its Affidavit of Assumption of Responsibility only pertained to obligations of seafarers recruited by its predecessor, Global Gateway Crewing Services, Inc., and not Skippers United Pacific, Inc., who originally hired Orlanes.
Previous Complaints and Developments
- Prior to the second complaint, Orlanes filed a first complaint against Skippers, Fairport, and Jerosalem P. Fernandez.
- The first complaint led to the dismis