Stolt-Nielsen Marine Services (Phils.), Inc. vs. NLRC, 264 SCRA 307, November 19, 1996.

Facts:
Eduardo was employed by Stolt-Nielsen (Company) to serve as an engine fitter on board a vessel
for ten months. However, on several instances during his employment on board the vessel, the
Captain ordered him to perform work which were not connected to his job description such as
cleaning the cargo tanks and performing berthing and unberthing operations on the ship. One
day, he failed to obey one of these commands due to an illness he was suffering then. The
Captain treated this as a refusal to perform work and/or as disobedience to a lawful order of a
superior. On this basis, his employment was terminated. He filed a case for illegal dismissal. The
Company claimed that the orders given to Eduardo were justified on the basis of a CBA
stipulation which provided that all officers regardless of rank shall provide assistance in works in
the engine room and in deck/tank cleaning.
Held:
In ruling that he was illegally dismissed, the Court held that such CBA provision is primarily for
computing extra compensation of the employee, and cannot be used to compel or force crew
members to regularly perform jobs other than what they have been contracted for. This is so
because otherwise, all crew members can be compelled to perform jobs other than what they
were contracted for and if they refuse, they could be terminated for insubordination. Such an
interpretation, according to the Court, would go contrary to the constitutional mandate of
protecting labor.