PHILIPPINE INTERNATIONAL SHIPPING CORPORATION, PETITIONER, VS. HONORABLE NATIONAL LABOR RELATIONS COMMISSION AND BRIGIDO SAMSON, REPRESENTED BY WIFE, NORMA S. SAMSON, RESPONDENTS.

Philippine International Shipping versus National Labor Relations Commission

The Case

This is a petition for certiorari brought by Philippine International Shipping Corporation against the National Labor Relations Commission and Brigido Samson, represented by his wife Norma Samson. The petitioner asks the Supreme Court to annul the resolutions of the National Labor Relations Commission which refused to quash an amended writ of execution issued to collect the unpaid balance of a disability compensation award. The case matters because it settles two questions every maritime and labor practitioner must know: whether a seaman's signed release truly waives the balance of a judgment award, and whether an award fixed in dollars violates the law against foreign currency obligations. It is a compact lesson on the finality of administrative decisions and on the protected character of workers' claims.

Procedural History

Brigido Samson filed a claim for disability compensation benefits and hospitalization expenses under his employment contract against Philippine International Shipping Corporation before the National Seamen Board. On April 2, 1981, the Executive Director of the National Seamen Board rendered a decision ordering the petitioner to pay the complainant disability compensation benefits and to pay his counsel attorney's fees, with payment coursed through the National Seamen Board. The petitioner appealed to the National Labor Relations Commission. On December 17, 1981, the Commission affirmed the appealed decision. After that decision became final, a writ of execution was issued and served on the petitioner. The Sheriff later reported that the petitioner had paid 18,000 pesos, which the private respondent accepted, as evidenced by a voucher and a Release document dated May 7, 1981, and that the Sheriff had refrained from collecting the balance pending the Board's action. On June 17, 1982, the Board issued an Order holding that the payment was at most partial compliance and not a waiver of the balance, including attorney's fees, and directed the issuance of an amended writ of execution. The petitioner moved to quash the amended writ; the Board denied the motion on July 26, 1982. The petitioner appealed to the National Labor Relations Commission, which dismissed the appeal on December 20, 1982. The petitioner then came to the Supreme Court by petition for certiorari.

Facts

Brigido Samson served as Second Engineer on the petitioner's vessel, the M/V Asean Knowledge, from May 31, 1980 until February 12, 1981, when he was repatriated due to illness. He filed a claim for disability compensation benefits and hospitalization expenses before the National Seamen Board. On April 2, 1981, the Board awarded him disability compensation benefits of 3,800 dollars or its equivalent in Philippine currency, plus attorney's fees of 380 dollars or its equivalent, payable through the National Seamen Board.

The petitioner appealed to the National Labor Relations Commission. While that appeal was pending, the petitioner offered 18,000 pesos to the private respondent. On May 7, 1981, the private respondent received the amount and signed a Release document declaring, among other things, that he accepted the validity and legality of his separation and expressed his intention to release the company from any claim arising from his employment. At the time he signed, he was still undergoing medical treatment for the injury he sustained on board the vessel.

On December 17, 1981, the Commission affirmed the Board's decision, and that decision became final. When the Sheriff served the writ of execution, the petitioner claimed the 18,000 pesos was full payment. The private respondent insisted it was accepted only as partial payment because he badly needed funds for his ongoing medical treatment. The Board agreed with the private respondent, treated the payment as partial compliance, and ordered execution for the balance and the attorney's fees. The petitioner's motion to quash failed, its appeal to the Commission was dismissed, and it elevated the matter to the Supreme Court.

Issues

• Whether or not the National Labor Relations Commission erred in not quashing the amended writ of execution despite the Release already executed by the private respondent.
• Whether or not the decision ordering payment of the award in the dollar standard is illegal because it violates the law against payment of domestic obligations in foreign currency.

Applicable Provisions

Republic Act Number 529, the law invoked by the petitioner, provides the statutory backdrop for the second issue:

While it is true that Republic Act No. 529 makes it unlawful to require payment of domestic obligations in foreign currency, this particular statute is not applicable to the case at bar.

The Court's own restatement of the statute shows that the prohibition is against requiring payment of domestic obligations in foreign currency, and the question is whether the award does exactly that.

Ruling

On the first issue, the Court upheld the Commission. A satisfaction receipt does not amount to a waiver, because the law does not consider valid any agreement to receive less compensation than that to which the worker is entitled. The Court quoted its earlier ruling:

has signed a satisfaction receipt does not result in waiver; the law does not consider as valid any agreement to receive less compensation than that the worker is entitled to recover.

The Court also relied on the Board's factual finding that the private respondent was constrained to accept the 18,000 pesos and sign the Release because he was still undergoing medical treatment and needed funds. Findings of fact of administrative bodies are entitled to respect absent fraud, imposition, or mistake, and findings of the National Labor Relations Commission are generally entitled to respect except when there is grave abuse of discretion, which the Court did not find. The Court added a telling circumstance: the Release was signed while the petitioner's appeal was pending, yet the petitioner never moved to dismiss that appeal or to have the case declared terminated on the ground of satisfaction of judgment. That omission negates any inference of an agreement that the payment was full satisfaction.

On the second issue, the Court held there was no violation of Republic Act Number 529. The award did not compel payment in dollars; it expressly allowed payment of its equivalent in Philippine currency. The fixing of the award in dollars rested on the parties' employment contract, which stipulated wages and benefits in dollars because the private respondent was an overseas seaman on board a foreign vessel, and the petitioner never controverted this.

The Court also stressed that the Commission's decision affirming the Board had long become final and was never challenged. The petitioner may not evade the effects of a final decision by later assailing the writ of execution issued pursuant to it.

Doctrine

First, a worker's signed satisfaction receipt or release does not operate as a waiver of the balance of a compensation award. The law does not consider valid any agreement to receive less compensation than that which the worker is entitled to recover. Second, findings of fact of administrative bodies such as the National Seamen Board and the National Labor Relations Commission are entitled to respect absent fraud, imposition, mistake, or grave abuse of discretion. Third, an award expressed in foreign currency but payable in its equivalent in Philippine currency does not violate Republic Act Number 529, especially where the dollar stipulation flows from the parties' employment contract for overseas service. Fourth, a final and executory administrative decision may no longer be assailed indirectly through an attack on the writ of execution issued to enforce it.

Disposition

The petition was dismissed for lack of merit, with costs against the petitioner, so the private respondent prevailed and the amended writ of execution for the balance of the award and attorney's fees stood.

Remember This

Memorize the line that a satisfaction receipt does not result in waiver, because the law does not consider valid any agreement to receive less compensation than that which the worker is entitled to recover. Examiners use this case to test releases and quitclaims in labor and maritime claims, the respect owed to administrative findings of fact, and the rule that a final award may not be evaded by attacking the writ that enforces it.