On 19 May 2025, the Supreme Court held that in a claim or dispute between a Filipino seafarer and their employer, the continuing and consistent objection of one party to voluntary arbitrators shall result in the application of the general rule in Republic Act No. 8042, as amended, that labor arbiters have jurisdiction over the claim or dispute.
In the case of Benjie Y. Tandayag v. Magsaysay Maritime Corporation, G.R. 256183, Benjie Tandayag (Mr. Tandayag) was hired as a laundry steward by Magsaysay Maritime Corporation (Magsaysay Maritime) for its foreign principal, Princess Cruise Lines, Ltd. (Princess Cruise Lines). While onboard the vessel Caribbean Princess, Mr. Tandayag suffered a work-related injury, leaving him permanently disabled and unfit for sea duties.
Mr. Tandayag demanded the payment of disability and other related benefits from Magsaysay Maritime and Princess Cruise Lines, which refused his claims. Thereafter, Mr. Tandayag filed a complaint which was eventually referred to a Panel of Voluntary Arbitrators, which decided in his favor.
Magsaysay Maritime and Princess Cruise Lines filed a petition for review with the Court of Appeals (CA), which granted the petition, finding that the voluntary arbitrators had no jurisdiction over the case.
Mr. Tandayag argued that there was a submission agreement executed by both parties which vested jurisdiction with the voluntary arbitrators. Magsaysay Maritime and Princess Cruise Lines, however, contested and objected to the voluntary arbitrators’ jurisdiction throughout the proceedings.
The Supreme Court (SC) upheld the decision of the CA on the ground that, under the Labor Code, money claims arising from employer-employee relations must be filed with the labor arbiter. On the other hand, disputes involving collective bargaining agreements (CBAs), company personnel policies, and all other matters upon the agreement of both parties fall under the jurisdiction of the voluntary arbitrators.
In this case, there was no CBA between the parties, as indicated in Mr. Tandayag’s contract of employment. Also, while there was a submission agreement executed by both parties, this does not automatically vest the voluntary arbitrators with jurisdiction if the other party interposes a consistent objection to such jurisdiction.
The SC emphasized that while it is the State’s policy to promote voluntary arbitration in settling labor disputes, the nature of voluntary arbitration requires that both parties categorically and unequivocally agree to be bound by the voluntary arbitrator.
This guide provides a general overview of the above transactions at the time of writing only and is not intended to be a comprehensive legal advice. This should also not be taken as an opinion on the topic. For more details and information, you may coordinate with any GVES Law Partner regarding the matter.
Atty. Feleo C. Quijano is an Associate at GVES Law.