GR 186158; (November, 2010) (Digest)
G.R. No. 186158 ; November 22, 2010
CAREER PHILIPPINES SHIP MANAGEMENT, INC., Petitioner, vs. GERONIMO MADJUS, Respondent.
FACTS
Respondent Geronimo Madjus was medically repatriated in 2001 due to Nephrolithiasis (kidney stones) during his contract with petitioner Career Philippines Ship Management, Inc. He was later re-hired in 2002 after passing a Pre-employment Medical Examination (PEME) and completed a new contract. In 2005, he filed a complaint for disability benefits. The Labor Arbiter and the NLRC ruled in his favor, awarding permanent total disability benefits.
While petitioner’s appeal via a Petition for Certiorari was pending before the Court of Appeals, the Labor Arbiter issued a Writ of Execution for the monetary award. To forestall execution, petitioner filed a “Conditional Satisfaction of Judgment Award” with the Labor Arbiter, paying the judgment award in full but expressly reserving its rights in its pending appeal. The Labor Arbiter then issued an Order stating the case was amicably settled and dismissed, without prejudice to the petition at the CA.
ISSUE
Whether the Court of Appeals correctly dismissed petitioner’s appeal as moot and academic due to its voluntary payment of the judgment award.
RULING
Yes. The Supreme Court affirmed the dismissal. The payment, though labeled “conditional,” constituted a voluntary satisfaction of the judgment award. By paying the full amount to prevent execution, petitioner effectively acquiesced to the enforceability of the Labor Arbiter’s Decision. The express reservation in the pleading did not alter the legal effect of the payment, which was an act of compliance with a final and executory judgment. The law intends appeal bonds to secure the award pending appeal; voluntary payment renders the appeal moot. The Labor Arbiter’s subsequent Order of dismissal, based on the payment, solidified the final settlement of the monetary claims. Consequently, the CA correctly declined to review the merits, as no actual controversy remained for resolution. The petition was denied.