G.R. No. 209383 , March 11, 2013
SEACREST MARITIME MANAGEMENT, INC., ROLANDO B. MAGCALE, AND SEALION SHIPPING LIMITED – UNITED KINGDOM, Petitioners, vs. MAURICIO G. PICAR, JR., Respondent.

FACTS

Respondent Mauricio Picar, Jr., employed as Chief Cook by petitioners, was repatriated on October 2, 2010, after being diagnosed with Urinary Tract Infection and Renal Calculus. Upon arrival, he was referred to a company-designated physician. A private physician later declared him unfit for work. Picar filed a complaint for permanent disability compensation and other benefits. The Labor Arbiter ruled in his favor, awarding US$60,000.00 as permanent disability compensation, among other amounts. The NLRC affirmed the decision. Petitioners elevated the case to the Court of Appeals via a petition for certiorari under Rule 65. Meanwhile, Picar moved for execution. A Writ of Execution was issued, and petitioners paid the judgment award as evidenced by a Satisfaction of Judgment. The Court of Appeals dismissed the petition for certiorari, ruling it had become moot and academic due to petitioners’ payment of the award, citing Career Philippines Ship Management, Inc. v. Madjus.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing the petition for certiorari for having become moot and academic due to petitioners’ satisfaction of the judgment award under a writ of execution.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Court of Appeals’ Decision and Resolution, and REMANDED the case to the Court of Appeals for decision on the merits. The Court held that the petition for certiorari was not rendered moot by the satisfaction of the judgment award. The ruling in Career Philippines was based on equitable considerations where a “conditional settlement” was deemed an amicable settlement, which was not the situation here. Instead, the case of Leonis Navigation v. Villamater and Philippine Transmarine Carriers, Inc. v. Legaspi were more applicable. In those cases, the Court held that the satisfaction of a monetary award, especially when done in compliance with a writ of execution and without a voluntary settlement agreement between the parties that extinguishes the obligation, does not render a pending petition for certiorari moot. Here, petitioners’ payment was made in strict and compulsory compliance with the writ of execution, and there was no document executed between the parties akin to an amicable settlement. Therefore, the CA erred in dismissing the petition outright without resolving it on its merits.