Case Summary (G.R. No. 81805)
Factual Background and Procedural History
The petitioners filed a complaint with the POEA Workers Assistance and Adjudication Office against the private respondents, accusing them of breaching their contracts and causing damage. A hearing was held on March 4, 1987, where the parties agreed to submit position papers and then consider the case submitted for decision. Only the respondents submitted their position papers. On September 9, 1987, the POEA Administrator issued a decision dismissing the case with reprimands and ordering various payments from the petitioners to respondents.
Contents of the POEA Administrator’s Decision
The decision dismissed the case against most respondents with warnings, excluded one individual (Ricardo Llanes), reprimanded the complainant (Var-Orient Shipping Co.) for non-compliance with POEA rules, archived the names of some respondents and placed them on a POEA watchlist, and ordered joint and several payments to the respondents for deductions and attorney’s fees. Specifically, Edgar T. Bunyog was awarded payment for unserved salaries and attorney’s fees.
Service of Decision and Petitioners’ Knowledge
The decision was purportedly served by registered mail to petitioners' former counsel, Attorney Francisco B. Figura, on September 21, 1987. However, Attorney Figura contended he never received the decision. Petitioners reportedly only learned about the decision when the writ of execution was served on November 20, 1987. Subsequently, through new counsel, they filed a motion to recall the writ of execution on the ground that the decision was not yet final and executory as it had not been received.
Issues Raised by the Petitioners
Petitioners argued: (1) that the issuance of the writ of execution was premature without formal receipt of the decision; (2) denial of due process because the decision was rendered without a formal hearing; (3) the denial of their right to appeal; and (4) the award of damages was excessive and unfounded.
Court’s Ruling on Service and Finality of Decision
The Court found petitioners’ claim that they did not receive the decision unconvincing, as the registered mail was delivered to the counsel’s office receptionist and no affidavit was submitted from the receptionist to clarify the handling of the decision. The Court held that service was proper and the decision therefore final and executory. The denial of their urgent motion to recall the writ of execution was justified.
Court’s Analysis on Due Process
The Court emphasized that due process in administrative proceedings requires only an opportunity to be heard or to explain one’s side, or an opportunity to seek reconsideration. The parties agreed at hearing to submit memoranda and then consider the case submitted. While only respondents filed memoranda, petitioners did not oppose motions for resolution and ex
...continue readingCase Syllabus (G.R. No. 81805)
Facts of the Case
- Petitioners Var-Orient Shipping Co., Inc. and Comninos Bros. filed a petition assailing the decision dated September 9, 1987, of the POEA Administrator Tomas D. Achacoso in POE CASE No. (M) 86-11-1080.
- The case arose from a complaint filed by the petitioners with the Workers Assistance and Adjudication Office of the Philippine Overseas Employment Administration against the private respondents — Edgar T. Bunyog, Vedasto Navarro, Eugenio Capalad, Raul Tumasis, Antonio Tanio-an, Celestino Cason, Danilo Manela, and Roberto Genesis.
- These private respondents were crew members of the MPV "Silver Reefer" who allegedly violated their contracts of employment, resulting in damages due to the vessel’s interdiction by the International Transport Workers Federation (ITF) at Kiel Canal, Germany, in March 1986.
- After joinder of issues, the hearing was held on March 4, 1987; parties agreed to submit position papers and then the case to be submitted for decision.
- Only private respondents submitted their position paper; petitioners did not.
- On September 9, 1987, the POEA Administrator rendered judgment dismissing the case with reprimands and warnings to several respondents, excluding Ricardo Llanes from the case, reprimanding the complainant Var-Orient Shipping Co. for violations, and ordering payments totaling several thousand pesos and US dollars to certain respondents as damages and attorney’s fees.
Procedural History
- The decision was sent by registered mail and delivered to petitioners’ counsel, Attorney Francisco B. Figura, on September 21, 1987 at his business address via receptionist Marlyn Aquino.
- Attorney Figura denied receipt of the decision envelope.
- Petitioners allegedly only learned of the decision when the writ of execution was served on November 20, 1987.
- Petitioners, through new counsel Atty. Quintin Aseron, Jr., filed an Urgent Motion to Recall the Writ of Execution on November 23, 1987, arguing that the decision was not yet final and executory as it was not formally received.
- The public respondent denied the motion on January 19, 1988.
- Petitioners filed the present petition alleging grave abuse of discretion on grounds of denial of due process, premature execution of decision, and awarding excessive and unfounded damages.