G.R. No. 265454 - ADAN DE GUZMAN HISANZA,*, VS. BRIGHT MARITIME CORPORATION, NAVIOS SHIPMANAGEMENT, INC., DESIREE P. SILLAR, GEORGIOS STEFANOU, NATIVIDAD B. EBRON, CLARISSA C. MENDOZA, RHODORA S. TABOADA, KONSTANTINA STEFANOU, AND WEBENA D. DABUCO,***.D E C I S I O N - Supreme Court E-Library

Ruling

accordingly entitled to the appropriate disability compensation. The NLRC thus committed grave abuse of discretion when it denied Hisanza's motion for reconsideration without passing upon this threshold issue; and the CA committed reversible error in affirming such ruling. Hisanza's belated pleader of the issue on reconsideration before the NLRC is not fatal to his case. Article 227 of the Labor Code relaxes the strict application of the rules on evidence in labor cases and authorizes the NLRC and the Labor Arbiters to exercise all just and reasonable means to establish the facts in each case. [80] More importantly, proceedings before the labor adjudication agencies are administrative in nature and are therefore not strictly bound by technical rules of procedure. [81] The validity of the December 2017 assessment was raised before the NLRC in the proper course of appeal, with the relevant evidence needed for its resolution already submitted. Crucially, respondents were adequately heard on the matter before the NLRC, the CA, and this Court. [82] As Hisanza is considered permanently and totally disabled ipso jure by virtue of his employers' failure to issue a valid final assessment and their reliance on an interim assessment to justify the premature cessation of the required treatment under the POEA-SEC, the issue regarding the lack of a third-doctor referral has been rendered moot. There being no evidence to justify any personal liability on the part of respondents Sillar, Georgios, Ebron, Mendoza, Taboada, Stefanou, and Dabuco in connection with Hisanza's claims, the obligation should vest upon respondents Bright and Navios only, being the parties named in the employment contract. [83] Under Section 32 of the POEA-SEC and its disability allowance schedule, the award for total and permanent disability (treated as impediment grade 1) is USD 60,000.00 [USD 50,000.00*120.00%]. [84] We find no reason to reverse the unanimous award of attorney's fees by all three tribunals a quo . In labor proceedings, withholding of wages or benefits need not be attended by malice or bad faith to merit an award of attorney's fees; all that is needed is that lawful wages or benefits be unjustifiably withheld, thereby compelling the employee to litigate. [85] We also find no cogent reason to reverse the common rulings of the RAB, the NLRC, and the CA on moral and exemplary damages, there being no recorded indication of any bad faith or malicious conduct on the part of respondents that would entitle Hisanza to such damages. Finally, the total judgment award shall earn interest at the legal rate, following case law. [86] ACCORDINGLY , the petition is PARTIALLY GRANTED . The December 14, 2021 Decision and the January 4, 2023 Resolution of the Court of Appeals in CA-G.R. SP No. 168160 are REVERSED and SET ASIDE insofar as it awarded USD 7,465.00 in disability benefits and PHP 98,559.00 in sickness allowance to petitioner Adan De Guzman Hisanza. Judgment is hereby rendered OR