GR 211302; (August, 2015) (Digest)
G.R. No. 211302 , August 12, 2015
PHILIPPINE TRANSMARINE CARRIERS, INC., CARLOS C. SALINAS, AND NORWEGIAN CREW MANAGEMENT A/S, PETITIONERS, VS. CESAR C. PELAGIO, RESPONDENT.
FACTS
Respondent Cesar C. Pelagio was hired by petitioners as a Motorman. He experienced medical issues and was repatriated. The company-designated physician diagnosed him with conditions assessed as a Grade 11 disability. A private physician assessed him with a Grade 8 disability and declared him permanently unfit for work. Pelagio filed a complaint for disability benefits. The Labor Arbiter awarded him benefits corresponding to a Grade 11 disability. The NLRC reversed the Labor Arbiter, awarding Pelagio permanent total disability benefits. During the pendency of petitioners’ certiorari petition before the Court of Appeals (CA), the parties executed a Satisfaction of Judgment, wherein petitioners paid Pelagio the amount awarded by the NLRC. The document stated the payment was “without prejudice” to the pending certiorari petition and was made to prevent imminent execution. Pelagio executed a Receipt of Payment and an Affidavit recognizing the payment was without prejudice to the petition and acknowledging the NLRC’s jurisdiction over restitution in case of reversal. The NLRC approved the settlement and considered the case closed. The CA dismissed the certiorari petition, ruling that the Satisfaction of Judgment was a compromise agreement that rendered the issues moot and academic.
ISSUE
Whether or not the execution of the Satisfaction of Judgment between the parties rendered the certiorari proceedings before the CA moot and academic.
RULING
No. The Supreme Court ruled that the CA incorrectly dismissed the petition. The Satisfaction of Judgment, while a compromise agreement, was conditional as it was expressly made “without prejudice” to the pending certiorari petition. Such an agreement does not render the case moot because it does not preclude the employer from recovering the payment should the courts ultimately rule in its favor. The Court cited Leonis Navigation Co., Inc. v. Villamater, which held that a similar agreement did not moot the controversy. The Court distinguished the case from Career Philippines Ship Management, Inc. v. Madjus, noting that the agreement here contained explicit reservations preserving the parties’ rights pending the petition’s outcome. Since the CA’s dismissal was not on the merits, the Supreme Court reinstated and remanded the certiorari petition to the CA for resolution on the merits.