Case Summary (G.R. No. 119080)
Employment Contract and Incident Background
On May 22, 1990, Sangil signed an employment contract with Singa Ship Management Phils., Inc. on behalf of Royal Cruise Line for a one-year position as utility man/assistant steward on the Crown Odyssey, with a monthly salary of $50 plus tips. Following his departure to join the vessel on June 2, 1990, an altercation occurred on July 20, 1990, between Sangil and the Greek steward Athanasius Zakkas during passenger disembarkation, resulting in physical injury to Sangil. Sangil was pushed by Zakkas, fell, and sustained a head injury requiring medical attention.
Response to the Incident
After the incident, Sangil reported to the Philippine Embassy and subsequently informed the ship's captain about his intention to leave due to fears for his safety and ongoing harassment from the Greek crew. He was temporarily hospitalized and was repatriated to the Philippines on July 24, 1990. Subsequently, on March 6, 1991, he filed a complaint with the Philippine Overseas Employment Agency (POEA) seeking redress for illegal dismissal and unpaid salaries.
Procedural History
The POEA initially dismissed Sangil's complaint on March 20, 1992, citing lack of merit, arguing that he voluntarily signed off from the vessel. However, upon appeal, the National Labor Relations Commission (NLRC) reversed this decision on December 14, 1994, ordering the employers to pay Sangil $500 for his unexpired contract period and attorney's fees, while dismissing claims for overtime pay and tips.
Arguments of the Petitioners
In appealing the NLRC's decision, the petitioners contended that there was no illegal dismissal, positing that Sangil's actions were voluntary and self-induced, arguing he was the aggressor in the altercation. They claimed that the evidence supported their position, alleging Sangil's departure was an act of his own making.
NLRC Findings and Legal Reasoning
The NLRC's findings, which were upheld by the court, indicated that Sangil was not the aggressor but a victim who was pushed, as supported by the ship's logbook. The court emphasized that Sangil's response to the incident was grounded in legitimate fear for his safety and that his departure from the vessel was not voluntary but motivated b
...continue readingCase Syllabus (G.R. No. 119080)
Case Background
- Petitioners Singa Ship Management Phils., Inc. and Royal Cruise Line are involved in a legal dispute with respondent Mario Sangil.
- The case arises from a complaint filed by Sangil against the petitioners for illegal dismissal and unpaid wages.
- Sangil had signed a twelve-month employment contract with Singa on May 22, 1990, to work on the cruise vessel Crown Odyssey.
- His basic monthly salary was set at US $50.00, supplemented by tips.
Incident Overview
- Sangil boarded the Crown Odyssey on June 2, 1990, unaware of existing tensions between Filipino and Greek crew members.
- On July 20, 1990, an altercation occurred with Greek deck steward Athanasius "Thanasi" Zakkas while disembarking passengers in Stockholm, Sweden.
- During the scuffle, Sangil was pushed by Zakkas and sustained a head injury that required medical attention.
- Following the incident, Sangil reported the situation to the Philippine Embassy and was hospitalized for observation.
Legal Proceedings
- Sangil filed a complaint with the Philippine Overseas Employment Agency (POEA) on March 6, 1991, seeking redress for illegal dismissal and wage claims.
- The POEA dismissed his complaint on March 20, 1992, stating that Sangil "voluntarily signed off from the vessel