Case Summary (G.R. No. 206555)
Facts of the Case
On May 8, 2008, Sarmiento was hired for a seven-month contract as Chief Mate, which was extended before he was repatriated due to health issues diagnosed while docked in Nigeria. Following his return, Sarmiento filed a labor complaint against Sea Gem and several individuals for unpaid wages and other claims, including petitions against the petitioners who denied all liability, asserting they were no longer employees during the relevant period.
Labor Arbiter Ruling
In a January 19, 2010 decision, the Labor Arbiter found petitioners and others jointly liable for Sarmiento's claims of unpaid salaries and sickness allowance, awarding him a total of US$32,821.00. The Arbiter denied claims for disability benefits and reimbursements due to inadequate evidence. The Arbiter's decision asserted that corporate officers could not escape liability merely by resigning.
NLRC Appeal
Petitioners appealed to the NLRC, reiterating non-liability and emphasizing no direct connection to Sarmiento’s employment at the time of his claims. On September 30, 2010, the NLRC affirmed the Labor Arbiter’s decision but modified it by absolving petitioners of liability based on the lack of their connection to Sea Gem at the time. The NLRC's ruling was not appealed by other parties involved.
Court of Appeals Proceedings
Sarmiento filed a certiorari petition to the Court of Appeals on April 7, 2011, arguing that the NLRC had abused its discretion. Petitioners contended that Sarmiento’s petition was filed beyond the allowable period, emphasizing that notices served to a counsel of record are binding on the client. The Court of Appeals did not address this timeliness issue directly but ruled to reinstate the Labor Arbiter’s decision on October 23, 2012, finding petitioners liable based on their roles during Sarmiento's employment period.
Supreme Court's Ruling
The Supreme Court ruled favorably for the petitioners, concluding that Sarmiento’s appeal to the Court of Appeals was filed out of time as it was not timely noted from the correct date of notice to Atty.
...continue readingCase Syllabus (G.R. No. 206555)
Case Overview
- The case involves a petition for review on certiorari regarding the decision of the Court of Appeals (CA) that reversed the ruling of the National Labor Relations Commission (NLRC).
- The petitioners, Atty. Fortunato Pagdanganan, Jr., Atty. Abigail D. Suarez, and Eugenio A. Villanueva, were previously absolved of any liability concerning the labor complaint filed by respondent Florentino P. Sarmiento.
Factual Background
- On May 8, 2008, Sea Gem Maritime International, Inc. hired Sarmiento as Chief Mate of the vessel M/T Intuition for an initial duration of seven months.
- Sarmiento boarded the vessel on May 10, 2008, and the contract was extended for two months upon expiration on December 10, 2008.
- Subsequently, Sarmiento was transferred to M/T Setubal I, where he continued as Chief Mate.
- On January 14, 2009, while docked in Nigeria, Sarmiento experienced health issues leading to a diagnosis of Mild Cardiovascular Stroke and other medical conditions, resulting in his repatriation on January 18, 2009.
Labor Complaint
- On July 7, 2009, Sarmiento filed a complaint against various parties, including the petitioners, for unpaid salaries, disability benefits, sickness allowance, and reimbursement of medical expenses.
- The petitioners denied any liability, asserting their resignation from Sea Gem prior to Sa