G.R. No. 246960 , July 28, 2020
Interorient Maritime Enterprises, Inc. and/or Interorient Maritime, DMCC for and in behalf of Wilby Marine Ltd., and/or Daisy S. Sumo, Petitioners, vs. Ildefonso T. Hechanova, Respondent.

FACTS

In February 2015, petitioner Interorient Maritime Enterprises, Inc. hired respondent Ildefonso T. Hechanova as a master for a nine-month contract. On June 24, 2015, after three months, Hechanova was relieved from duty in Amsterdam and repatriated, with a promise of redeployment. Upon arrival in the Philippines, he reported to Interorient’s office, underwent a medical examination, and was declared fit for duty on June 30, 2015. On July 3, 2015, Hechanova fell ill, was hospitalized, and was later assessed as unfit to work. His request for medical assistance from Interorient was denied due to lack of submitted medical documents. Hechanova filed a complaint solely for total and permanent disability benefits. Interorient contended his illness was not work-related and occurred after his employment ended, noting Hechanova had previously indicated no illnesses or injuries during his employment and had no complaints. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed Hechanova’s claim, finding no proof his illness was work-related. The Court of Appeals affirmed the denial of disability benefits but modified the decision by awarding Hechanova full reimbursement of placement fee and deductions with interest, salary for the unexpired portion of his contract, and attorney’s fees, based on a finding of illegal dismissal. Interorient filed this petition.

ISSUE

Whether or not the Court of Appeals erred in modifying the NLRC’s decision and awarding reimbursement of placement fee and deductions with interest, salary for the unexpired portion of the employment contract, and attorney’s fees, despite these not being prayed for in Hechanova’s complaint.

RULING

The petition is meritorious. The Supreme Court modified the Court of Appeals decision. The Court ruled that courts cannot grant relief not prayed for in the pleadings or in excess of what is sought by a party, as it violates due process by surprising the opposing party who lacks opportunity to be heard on the unpleaded issues. Hechanova’s complaint was exclusively for total and permanent disability benefits; he did not allege illegal dismissal or pray for the monetary awards granted by the Court of Appeals. Consequently, the Court of Appeals erred in sua sponte finding illegal dismissal and awarding corresponding monetary relief. The Supreme Court deleted the Court of Appeals’ findings of illegal dismissal, the award of reimbursement for placement fee and deductions with interest, salary for the unexpired contract portion, and attorney’s fees.