Almirante: Satisfaction of judgment pending certiorari

PETITIONER Marino B. Daang, a seafarer, filed a complaint for total permanent disability benefits and damages against respondents Skippers United Pacific Inc. and Commercial S.A.

The Labor Arbiter (LA) found in favor of Daang which decision was affirmed by the National Labor Relations Commission (NLRC). The Court of Appeals (CA) reversed the decision of the NLRC.

On Sept. 6, 2011, while the case was pending resolution before the Supreme Court, Daang filed an urgent manifestation with motion to dismiss alleging that on March 10, 2009, the parties jointly executed and filed with the NLRC a “conditional satisfaction of judgment with urgent motion to cancel appeal bond all without prejudice to the pending petition for certiorari in the Court of Appeals.” Daang claimed that he received from respondents the amount of P2,985,129 as “conditional payment of the judgment award of the LA only to prevent imminent execution” of the NLRC ruling.

Does the motion find merit?

Ruling: Yes.

We grant petitioner’s motion and consider the case before the CA moot and academic.

In a nutshell, the documents above enabled respondents to prevent the execution of the NLRC decision, maintain their petition before the CA, and in the event of an unfavorable outcome, seek an appeal before us. Daang, on the other hand, would not only be obliged to return all settlement money he received in the event that the CA reverses the NLRC, by his waiver of his claims and right to prosecute any further action, he also gave up any legal recourse which would otherwise have been available to him. Clearly, Daang is on the losing end. The terms of the Conditional Satisfaction of Judgment and the Affidavit, not unlike those considered by this Court in Hernandez vs. Crossworld Marine Services Inc., are highly unfair and prejudicial against him.

Applying Hernandez vs. Crossworld Marine Services Inc., we find the respondents to be in bad faith and should therefore bear the consequence of their actions. The conditional payment of the judgment award to Daang will be treated as a voluntary settlement in full satisfaction of the NLRC’s judgment. With the judgment award satisfied as of March 10, 2009—when the parties signed and filed the Conditional Satisfaction of Judgment with the NLRC, respondents’ petition before the CA became moot and academic. We reject respondents’ contention that the Conditional Satisfaction of Judgment is their only protection against the execution proceedings before the NLRC. Respondents are not compelled to immediately pay the judgment award. In fact, they had already filed with the NLRC an appeal bond intended as an assurance to Daang that he would receive the money judgment upon dismissal of respondents’ appeal. (Marino B. Daang vs. Skippers United Pacific Inc., et al., G.R.191902, July 30, 2019).


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