G.R. No. L-65442. April 5, 1985.
HAVERTON SHIPPING LTD. and OFSI SERVICES, INC., petitioners, vs. THE NATIONAL LABOR RELATIONS COMMISSION, THE HON. CRESENCIO M. SIDDAYAO, in his capacity as Officer-in-Charge of the NATIONAL SEAMEN BOARD and ALFREDO BENITEZ, respondents.

FACTS

Petitioners Haverton Shipping Ltd. and its manning agent, OFSI Services, Inc., hired respondent Alfredo Benitez as a boatswain for a one-year contract. On May 24, 1982, while the vessel was docked in Durban, South Africa, an altercation occurred involving Benitez and two crewmates, resulting in an injury to Maximo Espiritu’s hand. The ship’s Master conducted an investigation, documented in the official log book, finding Benitez breached the disciplinary code on multiple counts, including assault with a knife, absence from duty, and behavior detrimental to the ship’s safety. Benitez was subsequently repatriated. He filed a complaint with the National Seamen Board (NSB) for payment of his salary for the unexpired portion of his contract, claiming Espiritu, who was drunk, was the aggressor and that any injury was self-inflicted during a struggle. The NSB ruled in favor of Benitez, a decision affirmed by the National Labor Relations Commission (NLRC), ordering the petitioners to pay the claimed salaries.

ISSUE

Whether or not the termination of Alfredo Benitez before the expiration of his contract was for a just cause.

RULING

Yes, the termination was for a just cause. The Supreme Court granted the petition for certiorari, reversing the NLRC and NSB decisions. The Court emphasized the high probative value of the entries made by the ship’s Master in the vessel’s official log book, which under the Code of Commerce are considered prima facie evidence of the facts stated therein. The log book meticulously detailed the investigation, the charges against Benitez (absenteeism, assault with a knife, intimidation), and crucially, contained Benitez’s own admission of guilt during the hearing. The Master’s subsequent explanatory letter clarified that a “very good” discharge rating was given to not unduly ruin Benitez’s future career, but did not negate the factual findings of misconduct. Benitez’s uncorroborated affidavit, alleging drunken provocation and self-inflicted injury by Espiritu, was insufficient to overcome the weight of the official log book entries. The Court held that Benitez’s actions constituted serious misconduct, a just cause for dismissal under the Labor Code. Consequently, he was not entitled to salaries for the unexpired contract period. The temporary restraining order was made permanent.