Labor Law Digest: PHILIPPINE INTERNATIONAL SHIPPING CORPORATION v. HONORABLE NATIONAL LABOR RELATIONS COMMISSION et al (G.R. No. L-63535, May 27, 1985)

Labor Law Digest: PHILIPPINE INTERNATIONAL SHIPPING CORPORATION v. HONORABLE NATIONAL LABOR RELATIONS COMMISSION et al (G.R. No. L-63535, May 27, 1985) 

FACTS:

The case stems from a claim for disability compensation benefits and hospitalization expenses under employment contract, filed by private respondent  Brigido Samson, against the petitioner before the National Seaman's Board (NSB). A decision was rendered on by the Executive Director of the NSB, ordering petitioner to pay complainant the sum of US $3,800.00 or its equivalent in Philippine Currency as disability compensation benefits, among others. Not satisfied with the foregoing judgment, petitioner appealed to the NLRC. During the pendency of said appeal, petitioner offered P18,000.00 to private respondent. Private respondent received said amount and executed a "Release" document.

The appealed decision was affirmed by the NLRC. During the scheduled hearing, private respondent maintained that the P18,000.00 was accepted by him only as partial payment of the award since he badly needed the money for his on-going medical treatment. Petitioner herein, however, insisted that said amount constituted full payment of the award.

An Order was issued by the Board, and then the amended Writ of Execution was forthwith issued. Petitioner however, filed a motion to quash the amended writ of execution. The Board denied the said motion. Petitioner appealed the denial of its motion to NLRC. NLRC rendered a resolution dismissing petitioner's appeal. Hence, this instant petition for certiorari.

ISSUES:
a) Whether or not the ordering payment of the award using the dollar standard, as affirmed by NLRC, is in violation of law.
b) Whether or not the payment of P18,000.00 under the document of release executed by private respondent constitutes full satisfaction of the award.

HELD:

a) NO. A careful reading of the decision rendered by the Executive Director of the NSB and which led to the Writ of Execution protested to by petitioner, will readily disclose that the award to the private respondent does not compel payment in dollar currency but in fact expressly allows payment of "its equivalent in Philippine currency. Moreover, the fixing of the award in dollars was based on the parties employment contract, stipulating wages and benefits in dollars since private respondent was engaged in an overseas seaman on board petitioner's foreign vessel. Thus, Republic Act No. 529 provision specifically making it unlawful to require payment of domestic obligations in foreign currency, is not applicable to the case at bar. 

b) NO. As held in the case of MRR Yard Crew Union versus Philippine National Railways, 72 SCRA 88 (1976), the fact that the employee "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."

Nonetheless, its worthnoting that despite the execution of said release document, the petitioner did not file any motion to dismiss its appeal or to have said appealed case declared terminated due to the alleged satisfaction of the judgment. This omission negates an inference that the parties had actually agreed that the payment of the P18,000.00 would be equivalent to a full satisfaction of the award and/or a waiver of the balance on the award.

WHEREFORE, the petition in this case is hereby dismissed for lack of merit. Costs against petitioner.