In Alenaje v. C.F. Sharp Crew Management, Inc., the Supreme Court affirmed that a seafarer’s resignation was voluntary, not a constructive dismissal, when the assigned task was within the scope of duties outlined in the POEA Standard Contract. This ruling emphasizes the importance of adhering to lawful commands and company policies, reinforcing the principle that a resignation is only considered constructive when employment conditions become unbearable due to the employer’s actions. The Court underscored the seafarer’s failure to provide clear, positive, and convincing evidence that his resignation was forced, thus upholding the sanctity of freely entered contracts and the obligations they entail.

Stripping Away Duties or Stripping Away Rights? A Seafarer’s Tale

Rommel S. Alenaje, a seafarer, filed a complaint for illegal dismissal against C.F. Sharp Crew Management, Inc., Reederei Claus-Peter Offen (GMBH & Co.), and Roberto B. Davantes (collectively, respondents), claiming he was constructively dismissed. Alenaje contended that he resigned due to being assigned tasks outside his job description as a steward, specifically being ordered to strip and wax the navigational bridge floor. This raised the core legal question: Was Alenaje’s resignation voluntary, or did the circumstances constitute constructive dismissal, entitling him to damages and the unexpired portion of his contract?

The Labor Arbiter (LA) initially ruled in favor of Alenaje, finding that he was constructively dismissed because the assigned task was not part of his duties as a steward. The LA awarded him Php 192,458.22, covering the unexpired portion of his employment contract, moral and exemplary damages, and attorney’s fees. However, the National Labor Relations Commission (NLRC) reversed the LA’s decision, stating that Alenaje voluntarily resigned. The NLRC emphasized that the order to clean the navigational bridge was a lawful command, and Alenaje failed to prove his continued employment was rendered impossible or unreasonable by the respondents’ actions. The Court of Appeals (CA) affirmed the NLRC’s decision, leading Alenaje to elevate the case to the Supreme Court.

The Supreme Court, in its analysis, first addressed the procedural issues raised by the respondents. They argued that Alenaje’s motion for reconsideration before the NLRC was filed beyond the reglementary period, rendering the NLRC decision final. The Court, citing Opinaldo v. Ravina, acknowledged the mandatory nature of perfecting an appeal within the statutory period but also recognized the NLRC’s discretion to liberally apply its rules. The Court deferred to the NLRC’s decision to give due course to the motion, emphasizing that the NLRC ultimately affirmed its original decision.

Time and again, we have ruled and it has become doctrine that the perfection of an appeal within the statutory or reglementary period and in the manner prescribed by law is mandatory and jurisdictional. Failure to do so renders the questioned decision final and executory and deprives the appellate court of jurisdiction to alter the final judgment, much less to entertain the appeal.

Another procedural point raised was the lack of signature on Alenaje’s motion for reconsideration of the CA’s decision. Respondents argued that this made the pleading ineffective. The Court noted that the CA had exercised its discretion by ruling on the merits of the motion, effectively waiving the technical defect. The Court then proceeded to address the substantive issue of whether Alenaje was constructively dismissed.

The Court emphasized that as Alenaje admitted to resigning, he bore the burden of proving that his resignation was involuntary and constituted constructive dismissal. Citing Gan v. Galderma Philippines, Inc., the Court distinguished between constructive dismissal and resignation:

x x x [C]onstructive dismissal is defined as quitting or cessation of work because continued employment is rendered impossible, unreasonable or unlikely; when there is a demotion in rank or a diminution of pay and other benefits. It exists if an act of clear discrimination, insensibility, or disdain by an employer becomes so unbearable on the part of the employee that it could foreclose any choice by him except to forego his continued employment.

The Court found that Alenaje failed to meet this burden. It noted that Section 1(B)(3) of the POEA Standard Contract obligates seafarers to obey the lawful commands of the master or any person who shall lawfully succeed him. The Court determined that the order to strip and wax the navigational bridge floor was a lawful command related to ship safety, thus falling within Alenaje’s duties. Affidavits from other seafarers corroborated this, stating that such tasks are occasionally assigned to stewards. This contrasted with Alenaje’s claim that such a task was beyond his responsibilities.

Furthermore, the Minutes of Hearing revealed that Alenaje admitted disregarding the order, claiming it was not his duty. The Court also discredited Alenaje’s claim that he politely requested to perform the task later, finding no support for this in his resignation letter or the hearing minutes. If he had already agreed and/or complied with the order, there would have been no need for the formal warning for insubordination.

The Supreme Court also dismissed Alenaje’s allegations of unbearable working conditions and maltreatment, deeming them self-serving due to lack of evidence. The Debriefing Report Alenaje filled out after his repatriation contradicted these claims, with positive feedback on policy matters, vessel conditions, and relationships with officers. Alenaje’s allegation of fear for his safety was also unsupported, as he remained on board the vessel for over a month after his resignation without incident. Thus, the court highlighted that,

Petitioner’s answers to the pertinent questions on the Debriefing Report are as follows:
Reason for s/off: RESIGN
x x x x
A. Feedback on Policy Matters:
1. Comments on principal general policies: Good
x x x x

This further undermined his claim of a hostile work environment that drove his resignation.

The Alenaje case underscores the importance of contractual obligations within the context of maritime employment. It highlights the seafarer’s duty to comply with lawful orders related to vessel operations and safety. The ruling serves as a reminder that allegations of constructive dismissal must be substantiated with clear and convincing evidence, especially when the seafarer has already tendered a resignation. The ruling reinforces the significance of truthfully and completely filling out documents related to the sign-off. Failing this, the courts might not lend credence to unsubstantiated claims later one.

FAQs

What was the key issue in this case?	The key issue was whether Rommel S. Alenaje’s resignation was voluntary or constituted constructive dismissal due to allegedly unbearable working conditions and assignment of tasks outside his job description.
What is constructive dismissal?	Constructive dismissal occurs when an employee’s working conditions become so intolerable due to the employer’s actions that the employee is forced to resign. It is considered an involuntary termination.
What is the POEA Standard Contract?	The POEA (Philippine Overseas Employment Administration) Standard Contract outlines the terms and conditions governing the employment of Filipino seafarers on board ocean-going vessels. It includes the duties and responsibilities of the seafarer.
What did the Labor Arbiter initially rule?	The Labor Arbiter initially ruled in favor of Alenaje, finding that he was constructively dismissed and awarding him damages and the unexpired portion of his contract.
How did the NLRC and Court of Appeals rule?	The NLRC reversed the Labor Arbiter’s decision, and the Court of Appeals affirmed the NLRC’s ruling, both finding that Alenaje voluntarily resigned.
What evidence weakened Alenaje’s claim?	Alenaje’s claim was weakened by his Debriefing Report, where he gave positive feedback on working conditions, and the affidavits of other seafarers who stated that cleaning tasks are sometimes assigned to stewards.
What is the significance of the Debriefing Report?	The Debriefing Report is a document filled out by seafarers upon repatriation, providing feedback on their employment experience. In this case, it contradicted Alenaje’s claims of maltreatment and unbearable conditions.
What duty do seafarers have under the POEA Standard Contract?	Under the POEA Standard Contract, seafarers have a duty to obey the lawful commands of the master or any person who shall lawfully succeed him, as well as comply with company policies and safety procedures.
What was the Court’s final decision?	The Supreme Court denied Alenaje’s petition, affirming the Court of Appeals’ decision that his resignation was voluntary and not a constructive dismissal.

The Supreme Court’s decision reinforces the importance of adhering to contractual obligations and providing substantial evidence to support claims of constructive dismissal. This case provides valuable guidance for both seafarers and employers in understanding their rights and responsibilities under the POEA Standard Contract.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ROMMEL S. ALENAJE VS. C.F. SHARP CREW MANAGEMENT, INC., G.R. No. 249195, February 14, 2022