G.R. No. 203478 , June 23, 2021
ARMANDO H. DE JESUS, PETITIONER, VS. INTER-ORIENT MARITIME ENTERPRISES, INC., INTER-ORIENT MARITIME ENT., INC. LIBERIA, GRIGOROUSSA I MARIN’E S.A.-MONROVIA LIBERIA, RESPONDENTS.

FACTS

Petitioner Armando H. De Jesus, a seafarer, had worked exclusively for respondent Inter-Orient Maritime Enterprises, Inc. for 20 years. On July 4, 2005, he executed a nine-month employment contract as Second Mate. During the seventh month, while the vessel was docked off Egypt, De Jesus experienced severe chest pains and breathing difficulty. He was admitted to a hospital in Egypt on March 28, 2006, and diagnosed with Acute Extensive Myocardial Infarction. He was cleared to travel back to the Philippines on April 7, 2006, but declared unfit for work and advised to undergo coronary angiography.
Upon arrival in the Philippines on April 12, 2006, De Jesus went to the respondent company’s office. He was told he needed to sign a Quitclaim to receive his unpaid salaries, which he signed due to exhaustion and desperation from his medical condition. The next day, a company-referred specialist confirmed his Myocardial Infarction. The company agreed to let him continue treatment in Cebu, his hometown, provided he sign a letter holding the company free from liability.
On April 18, 2006, company representatives accompanied De Jesus to the NLRC in Quezon City, where he signed several company-prepared documents: a computerized NLRC complaint form for non-payment of wages (docketed as NLRC NCR OFW Case No. 06-04-011699-00), a Quitclaim and Release, a Release of All Rights, and a pro-forma Motion to Dismiss. He received US$5,749.00. Consequently, Labor Arbiter Jovencio Ll. Mayor, Jr. issued an Order dated April 19, 2006, dismissing the complaint with prejudice.
De Jesus continued treatment in Cebu at his own expense. On February 12, 2007, he filed a new complaint before the NLRC in Cebu (NLRC RAB VII OFW Case No. 02-0014-2007) for disability benefits, sickness allowance, and damages. Respondents moved to dismiss on grounds of res judicata and the quitclaim. The Labor Arbiter denied the motion, finding the quitclaim was signed without counsel and for unconscionable consideration, and noted the irregularity of filing the complaint and motion to dismiss on the same day.
After submission of position papers, the Labor Arbiter ruled in favor of De Jesus on February 25, 2009, awarding permanent disability benefits (US$60,000.00), sickness allowance (US$3,200.00), less cash advance (US$5,749.00), plus attorney’s fees. The NLRC reversed this decision on September 30, 2009, holding that De Jesus failed to prove his illness was work-related and giving weight to respondents’ medical report. De Jesus filed a Petition for Certiorari with the Court of Appeals.
The Court of Appeals, in a Resolution dated November 23, 2010, dismissed the petition due to technical infirmities: failure to show dates of receipt of the NLRC decision and filing of the motion for reconsideration; failure to furnish the NLRC with a copy; attached copy of the assailed resolution was not a duplicate original or certified true copy; and the Verification and Certificate of Non-Forum Shopping lacked petitioner’s signature and did not conform to the 2004 Notarial Rules. A Motion for Reconsideration was denied on August 8, 2012. De Jesus then filed this Petition for Review on Certiorari before the Supreme Court.

ISSUE

1. Whether the Court of Appeals erred in dismissing the Petition for Certiorari based purely on procedural and technical grounds.
2. Whether the Court of Appeals erred in not resolving the petition on its merits and reinstating the Labor Arbiter’s Decision.

RULING

The Supreme Court granted the petition. On the procedural issue, the Court held that while procedural rules are important, they may be relaxed in the interest of substantial justice, especially in labor cases where the welfare of the working class is paramount. The technical defects in the CA petition were not fatal. De Jesus subsequently submitted documents to the Supreme Court showing compliance, including a certification of service to the NLRC and a properly signed Verification and Certificate of Non-Forum Shopping. Thus, the dismissal on technical grounds was improper.
On the substantive merits, the Supreme Court ruled in favor of De Jesus. The Court found that his illness, Acute Myocardial Infarction, is a cardiovascular disease listed as an occupational disease under Section 32-A of the POEA-SEC, and is thus presumed work-related. This presumption was not rebutted by the respondents. The medical report they submitted was prepared by a company-designated physician without a thorough examination and was conclusory, failing to provide a detailed assessment or explain why the illness was not work-related. Furthermore, the quitclaim and release were declared void. The consideration of US$5,749.00 was unconscionably low compared to the potential disability benefits of US$60,000.00. The documents were signed under exploitative circumstances—De Jesus was in a state of physical and financial distress, without the assistance of counsel, and the process was characterized by undue haste, with the complaint, quitclaim, and motion to dismiss all executed on the same day. Therefore, the quitclaim did not bar his subsequent claim.
The Supreme Court reinstated the Labor Arbiter’s Decision dated February 25, 2009, with modification, ordering respondents to jointly and severally pay De Jesus permanent disability benefits of US$60,000.00 and sickness allowance of US$3,200.00, minus the US$5,749.00 already received, plus 10% attorney’s fees, all with legal interest at 6% per annum from finality of judgment until full payment.