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PTC Vs Legaspi

This case involved a dispute over disability compensation between an employee (Respondent Legaspi) and his employer (Petitioner Philippine Transmarine Carriers). The employer paid the employee $81,320 based on a receipt that stated the amount would be returned if the employer's appeal was granted. The appeal was partially granted, reducing the amount to $60,000. The Court ruled that the receipt agreement was binding and that allowing the employee to keep the excess $29,452 would constitute unjust enrichment. The employee was ordered to return the excess payment plus interest to the employer.

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192 views

PTC Vs Legaspi

This case involved a dispute over disability compensation between an employee (Respondent Legaspi) and his employer (Petitioner Philippine Transmarine Carriers). The employer paid the employee $81,320 based on a receipt that stated the amount would be returned if the employer's appeal was granted. The appeal was partially granted, reducing the amount to $60,000. The Court ruled that the receipt agreement was binding and that allowing the employee to keep the excess $29,452 would constitute unjust enrichment. The employee was ordered to return the excess payment plus interest to the employer.

Uploaded by

tregine444
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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[ G.R. No.

202791, June 10, 2013 ]


PHILIPPINE TRANSMARINE CARRIERS, INC., PETITIONER, VS. LEANDRO LEGASPI, RESPONDENT.

FACTS: Respondent Leandro Legaspi was employed as Utility Pastry on board the vessel "Azamara Journey" under
the employment of petitioner Philippine Transmarine Carriers, Inc. Respondent's employment was covered by a
Collective Bargaining Agreement (CBA) wherein it was agreed that the company shall pay a maximum disability
compensation of up to US$60,000.00 only.

While on board the vessel, respondent suffered "Cardiac Arrest S/P ICD Insertation." He was checked by the ship's
doctor and was prescribed medications. On November 14, 2008, respondent was repatriated to receive further
medical treatment and examination. On May 23, 2009, the company- designated physician assessed his condition to
be Disability Grade 2.
Not satisfied, respondent filed a complaint for full and permanent disability compensation against petitioner before the
Labor Arbiter (LA) then to NLRC.
The NLRC affirmed the LAs decision. Notably, the LA awarded US$80,000.00 based on the ITF Cruise Ship Model
Agreement for Catering Personnel, not on the CBA.
During the hearing on the motion for execution before the NLRC, petitioner agreed to pay respondent US$81,320.00.
The terms and conditions of said payment were embodied in the Receipt of Judgment Award with Undertaking,
[4]

wherein respondent acknowledged receipt of the said amount and undertook to return it to petitioner in the event the
latter's petition for certiorari would be granted, without prejudice to respondent's right to appeal.
Petitioner timely filed a petition for certiorari with the CA.
In the meantime, the LA issued a writ of execution which noted petitioner's payment of the amount of US$81,320.00.
On March 16, 2011, in compliance with the said writ, petitioner tendered to the NLRC Cashier the additional amounts
of US$8,132.00 as attorney's fees and P3,042.95 as execution fee. In its Order, dated March 31, 2011, the LA
ordered the release of the aforementioned amounts to respondent.

Unaware of entry of judgment of the NLRC,the payment of US$81,320.00, and the writ of execution issued by the LA,
the CA rendered its Decision which partially granted the petition for certiorari and modified the assailed resolutions of
the NLRC, awarding only US$60,000.00 pursuant to the CBA between Celebrity Cruise Lines and
FederazioneItalianaaTransporti CISL.
Petitioner contended (to CA) that since it had already paid the total amount of US$89,452.00, it was entitled to the
return of the excess payment in the amount of US$29,452.00.

CA denied the motion and ruled that the petition should have been dismissed for being moot and academic not only
because the assailed decision of the NLRC had become final and executory, but also because the said judgment had
been satisfied, even before the filing of the petition for certiorari.

ISSUE: WON PETITIONER IS ESTOPPED IN COLLECTING THE EXCESS PAYMENT IT MADE TO THE
RESPONDENT NOTWITHSTANDING THE RECEIPT OF JUDGMENT AWARD SIGNED BY THE RESPONDENT/
WON to allow the respondent to retain excess money judgment would amount to his unjust enrichment to
the prejudice of the petitioner.
HELD: Return of Excess Payment

As the agreement was voluntarily entered into and represented a reasonable settlement, it is binding on the parties
and may not later be disowned simply because of a change of mind.
[18]
Respondent agreed to the stipulation that he
would return the amount paid to him in the event that the petition for certiorari would be granted. Since the petition
was indeed granted by the CA, albeit partially, respondent must comply with the condition to return the excess
amount.

The Court finds that the Receipt of the Judgment Award with Undertaking was a fair and binding agreement. It was
executed by the parties subject to outcome of the petition. To allow now respondent to retain the excess money
judgment would amount to his unjust enrichment to the prejudice of petitioner.

Unjust enrichment is a term used to depict result or effect of failure to make remuneration of or for property or
benefits received under circumstances that give rise to legal or equitable obligation to account for them. To be
entitled to remuneration, one must confer benefit by mistake, fraud, coercion, or request. Unjust enrichment is not
itself a theory of reconveyance. Rather, it is a prerequisite for the enforcement of the doctrine of restitution.
[19]
There
is unjust enrichment when:
1. A person is unjustly benefited; and
2. Such benefit is derived at the expense of or with damages to another.
[20]

WHEREFORE, the petition is GRANTED. The Court of Appeals Resolutions, dated January 5, 2012 and July 20,
2012, are hereby REVERSED and SET ASIDE. Respondent Leandro Legaspi is ORDERED to return the excess
amount of payment in the sum of US$29,452.00 to petitioner Philippine Transmarine Carriers, Inc. The amount shall
earn interest at the rate of 12% per annum from the finality of this judgment.

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