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Transglobal-Maritime-Agency-Inc-V-Chua-Jr (Decisions - Digest)

Chua was hired as an able seaman but was dismissed after returning late from shore leave. He filed a complaint claiming illegal dismissal. The Court of Appeals ruled that Chua's dismissal was illegal as his refusal to sign a written reprimand did not constitute insubordination. The CA ordered monetary awards to Chua and held that the legal interest rate on such awards is 6% annually. The CA has authority to review factual findings of labor tribunals and found the NLRC's decision was insufficiently supported by evidence in this case.

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162 views1 page

Transglobal-Maritime-Agency-Inc-V-Chua-Jr (Decisions - Digest)

Chua was hired as an able seaman but was dismissed after returning late from shore leave. He filed a complaint claiming illegal dismissal. The Court of Appeals ruled that Chua's dismissal was illegal as his refusal to sign a written reprimand did not constitute insubordination. The CA ordered monetary awards to Chua and held that the legal interest rate on such awards is 6% annually. The CA has authority to review factual findings of labor tribunals and found the NLRC's decision was insufficiently supported by evidence in this case.

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nash
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### G.R. No.

222430
## Transglobal Maritime Agency, Inc. v. Chua, Jr.
######
### Facts:
Transglobal Maritime Agency, Inc. (Transglobal), Goodwood Shipmanagement Pte., Ltd.
(Goodwood), and Michael Estaniel (petitioners) hired Vicente D. Chua, Jr. (Chua) as
an Able Seaman on M.T. WAWASAN RUBY on October 12, 2011. Chua's appointment letter
stated that he would serve for 9 months, with the first 3 months as a probation
period. On January 26, 2012, Chua and his companions returned late from shore leave,
which angered the ship captain. On January 30, 2012, Chua and the others were served
with a written reprimand, which they refused to sign. They were subsequently
dismissed and returned to the Philippines on February 3, 2012. Chua filed a complaint
for illegal dismissal, non-payment of salaries, withholding of documents, moral and
exemplary damages, and attorney's fees against the petitioners.
### Issue:
The main issue in this case is whether Chua's dismissal was valid.
### Ruling:
The Court of Appeals (CA) ruled that Chua's dismissal was illegal and ordered the
petitioners to pay him various monetary awards, including unpaid wages and benefits,
moral and exemplary damages, attorney's fees, and legal interest. The CA found that
Chua's refusal to sign the written reprimand did not constitute insubordination and
that his dismissal was disproportionate to the act complained of. The CA also held
that the correct rate of legal interest on the monetary awards is 6% per annum.
### Ratio:
The CA has the authority to review the factual findings of labor tribunals in labor
cases elevated to it via petition for certiorari under Rule 65. In this case, the CA
found that the NLRC's ruling was not sufficiently supported by evidence, and
therefore, it reversed and set aside the NLRC's decision. The employer bears the
burden of proving that the dismissal of an employee is for a just or authorized
cause. In this case, the petitioners failed to establish that Chua's refusal to sign
the written reprimand and the ship's logbook constituted insubordination. The pieces
of evidence presented were insufficient to establish that Chua's refusal was
characterized by a wrongful and perverse mental attitude. The CA also held that the
correct rate of legal interest on the monetary awards is 6% per annum.
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