Case Summary (G.R. No. 192565)
Applicable Law
The case is influenced primarily by the provisions of the Labor Code of the Philippines, the rules of the Philippine Overseas Employment Administration (POEA), and the corresponding provisions of the Civil Code governing contracts, specifically Articles 1370 and 1374.
Background of the Case
Nerry Balatongan was hired through Philimare Shipping, which served as a manning agent for foreign shipping companies, to work aboard a vessel owned by Turtle Bay Shipping. An employment contract, created on November 2, 1982, obligated the employer to insure Balatongan against disability or death caused by an accident on the ship. A supplementary agreement was made on December 6, 1982, outlining his insurance coverage.
Accident and Claim
Balatongan sustained a serious accident in the Suez Canal on October 6, 1983, which led to his hospitalization and eventual repatriation to the Philippines. A medical assessment issued on August 19, 1985, diagnosed him with a permanent disability, prompting him to file a demand for US$50,000.00 in insurance benefits. However, his claim was deemed time-barred as he failed to file it within the stipulated period.
Legal Proceedings
On June 21, 1985, Balatongan lodged a complaint against both Philimare and Seagull with the POEA for nonpayment of his disability claim. The POEA ruled in his favor, ordering both companies to pay him US$50,000.00. This decision was affirmed by the National Labor Relations Commission after Philimare and Seagull appealed. The case ultimately reached the Supreme Court, which held that the employers were liable for failing to assist Balatongan in filing his claim.
Manning Agency Agreement
On April 10, 1987, Southeast Asia Shipping Corporation entered into a Manning Agency Agreement with Navales, thereby taking on the role of recruiting agent. This agreement connected to a Special Power of Attorney that appointed SEASCORP as the agent for the hiring of Filipino seamen, subject to responsibilities for liabilities arising from that employment.
Trial Court Decision
Seagull subsequently filed a complaint against SEASCORP to recover the funds paid to Balatongan. The Regional Trial Court of Manila ruled in favor of Seagull, reasoning that SEASCORP’s Affidavit of Undertaking explicitly accounted for liabilities to all vessels of Navales.
Court of Appeals Ruling
Upon appeal to the Court of Appeals, SEASCORP contended that the trial court had erred in its interpretation of the Affidavit of Undertaking, claiming it only covered the vessel “Arawa Bay.” However, the appellate court upheld the lower court’s decision, asserting that the clear language in the Affidavit required SEASCORP to assume liabilities for all seamen previously deployed by SEAGULL.
Supreme Court Decision
The Supreme Court reversed the decision of the Court of Appeals. The Court emphasized that the language of the Affidavit of Undertaking was clear and left no room for interpreting it as covering only the “Arawa Bay
...continue readingCase Syllabus (G.R. No. 192565)
Case Overview
- The case involves a petition for review on certiorari by Southeast Asia Shipping Corporation (SEASCORP) against Seagull Maritime Corporation (SEAGULL) and the Court of Appeals, following a decision by the Regional Trial Court (RTC) of Manila.
- The appeal arises from a labor dispute concerning claims for disability insurance by Nerry Balatongan, an employee who suffered an accident while working aboard the vessel Santa Cruz, later renamed Turtle Bay.
Parties Involved
- Petitioner: Southeast Asia Shipping Corporation (SEASCORP)
- Respondents: Seagull Maritime Corporation (SEAGULL) and the Court of Appeals
- Claimant: Nerry Balatongan, a seaman who was employed by Philimare Shipping and later was involved in a dispute regarding his disability insurance claims.
Background of the Case
- On November 2, 1982, Balatongan was hired by Philimare Shipping, which was the manning agent for Navales Shipmanagement and Marine Consulting Pte. Ltd. of Singapore (NAVALES).
- A supplementary contract was executed on December 6, 1982, mandating that Balatongan would be insured against death or permanent invalidity due to accidents aboard the vessel.
- SEAGULL was appointed as the manning agent for NAVALES, which assumed responsibility for all seamen deployed by Philimare Shipping.
Incident and Claims
- On October 6, 1983, Balatongan met with an accident in the Suez Canal, leading to his hospitalization and subsequent repatriation to the Philippines.
- He was ultimately deemed permanently disabled on August 19, 1985, prompting him to file a claim