G.R. No. 199022 , April 7, 2014
Magsaysay Maritime Corporation, Petitioner, vs. Oscar D. Chin, Jr., Respondent.

FACTS

Petitioner Magsaysay Maritime Corporation, as agent for Thome Ship Management Pte. Ltd., hired respondent Oscar D. Chin, Jr. as an able seaman. On October 22, 1996, Chin sustained a work-related injury (lumbosacral strain) aboard the vessel. He was repatriated and later underwent surgery. On August 6, 1998, Chin accepted a disability compensation offer of US$30,000 from Pandiman Phils., Inc. (the local agent of Magsaysay’s P&I Club) and executed a Release and Quitclaim. Subsequently, Chin filed a complaint with the NLRC for underpayment of disability benefits and other claims. The Labor Arbiter and NLRC initially dismissed the complaint. The Court of Appeals reversed, awarding Chin permanent total disability benefits of US$60,000 and remanding the case for determination of other monetary claims. The Supreme Court denied Magsaysay’s petition against this CA decision, which became final. After Magsaysay paid the deficiency of US$30,000, the Labor Arbiter, on remand, awarded Chin various amounts including reimbursement for medical expenses, loss of future wages, moral and exemplary damages, and attorney’s fees. The NLRC deleted the awards for loss of future wages and moral and exemplary damages. The CA reinstated the Labor Arbiter’s Decision, prompting Magsaysay’s petition to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the Labor Arbiter’s award of loss of future earnings on top of disability benefits, as well as awards of moral and exemplary damages and attorney’s fees.

RULING

The Supreme Court PARTIALLY GRANTED the petition. It affirmed the CA Decision with modification. The award for loss of future earnings was deleted as it constituted double recovery, noting that the US$60,000 permanent total disability compensation already reasonably compensated Chin for injuries and loss of earning capacity. The Court found the Labor Arbiter’s awards of moral (₱200,000) and exemplary damages (₱75,000) excessive, reducing them to ₱30,000 and ₱25,000, respectively, due to insufficient proof of the degree of suffering. The award of ₱19,279.75 as reimbursement for medical expenses was affirmed. Attorney’s fees equivalent to 10% of the total awarded amounts (medical expenses, moral, and exemplary damages) were also granted. The defense of res judicata was rejected, as the subsequent proceedings were a continuation of the same action following a lawful remand.