The Supreme Court of the Philippines, in its decision on G.R. No. 231748 issued on July 8, 2020, addressed a serious case of sexual harassment against seafarer Toliongco aboard the M/V Mineral Water. After his deployment on February 23, 2014, an incident occurred on June 27, 2014, when Toliongco, while cleaning the galley, was approached by Chief Officer Korolenko Oleksiy who made unwanted sexual advances and threatened him. Despite his resistance and subsequent report to fellow crew members and the Captain, Toliongco experienced mental distress, resulting in a diagnosis of Post-Traumatic Stress Disorder (PTSD).
Toliongco filed a formal complaint involving claims of constructive dismissal, sexual harassment, and maltreatment after he feared for his safety due to threats from CO Oleksiy following his report. His repatriation on July 12, 2014, was subsequently linked to these events, as he claimed a hostile work environment made it impossible for him to continue working.
Two medical experts later supported his claims, diagnosing him with PTSD related to the harassment. Despite these aspects, Anglo-Eastern Crew, his employer, contended that he voluntarily terminated his contract and argued against his claims for disability benefits, claiming that he did not meet the requirement of a mandatory post-employment medical examination within three days of repatriation.
The Labor Arbiter initially found Toliongco to have been constructively dismissed but rejected his claim for disability benefits due to procedural lapses, although he was awarded damages for moral suffering. The National Labor Relations Commission upheld this decision but altered the damages awarded. Toliongco later appealed to the Court of Appeals, which dismissed his petition, leading him to seek further recourse through the Supreme Court.
In its ruling, the Supreme Court recognized the PTSD as work-related but emphasized that it was critical to establish a causal link to the seafarer’s working conditions to justify compensation under the law. While the Court acknowledged the incident of harassment, it ultimately concluded that Toliongco did not sufficiently prove that his condition was work-aggravated or that he had rendered himself incapacitated to comply with the necessary reporting requirements.
However, the Court found that Toliongco was indeed a victim of sexual harassment and should be compensated for moral damages due to the trauma he experienced. The Court increased the damages awarded for moral and exemplary damages to further remedy the injustice he faced.
In conclusion, the Court ruled that Toliongco was entitled to various compensatory amounts, including his unpaid salary for the unexpired portion of his contract, moral and exemplary damages, and attorney’s fees. This decision emphasized not only the legal protection for seafarers but also the need for workplaces to ensure safety and prevent such harassment.
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