Facts:

The case involves petitioners Edgardo Doruelo and Anthony Estenzo, who were the captain and chief mate, respectively, of the LSCO Petroparcel, a steel tanker owned by the Luzon Stevedoring Corporation. The respondents include the Ministry of National Defense, the Philippine Coast Guard, and Maria Efigenia Shipping Corporation. The incident in question occurred on September 21, 1977, when a maritime collision took place between the LSCO Petroparcel and the MB Maria Efigenia XV, a fishing boat owned by Maria Efigenia Shipping Corporation. The collision resulted in the sinking of the fishing boat. Following the incident, Captain Doruelo filed twin marine protests regarding the collision. The Philippine Coast Guard conducted an inquiry and found that the LSCO Petroparcel, as the overtaking vessel, was required to keep out of the way of the fishing boats, which were the overtaken vessels. The Coast Guard's decision, issued on November 21, 1978, suspended Doruelo and Estenzo fo...

Facts:

1. Parties Involved:

   • Petitioners: Captain Edgardo Doruelo and Chief Mate Anthony Estenzo, officers of the LSCO Petroparcel, a steel tanker owned by Luzon Stevedoring Corporation.
   • Respondents: Ministry of National Defense, Philippine Coast Guard, and Maria Efigenia Shipping Corporation, owner of the fishing boat MB Maria Efigenia XV.

2. Incident:

   • On September 21, 1977, a maritime collision occurred between LSCO Petroparcel and MB Maria Efigenia XV, resulting in the sinking of the fishing boat.
   • Both vessels were headed in the same direction, with LSCO Petroparcel overtaking MB Maria Efigenia XV, which was towing another fishing boat, MB Maria Efigenia XI.

3. Marine Protests:

   • Twin marine protests were filed by Captain Doruelo (master of LSCO Petroparcel) and Patron Delfin Villarosa (master of MB Maria Efigenia XV).

4. Initial Decision by Philippine Coast Guard:

   • Captain Doruelo and Chief Mate Estenzo were suspended for two years from practicing their marine profession and disqualified from boarding any vessel during the suspension.
   • Patron Delfin Villarosa was exonerated but admonished to maintain composure in similar situations.

5. Appeal to Ministry of National Defense:

   • The Ministry affirmed the Philippine Coast Guard's decision but increased Captain Doruelo's suspension to three years based on his alleged involvement in another sea collision.

6. Petitioners' Claims:

   • Captain Doruelo claimed he altered course to avoid the fishing boat and an unidentified dry cargo vessel, but the fishing boat allegedly followed and collided with his vessel.
   • The Board of Marine Inquiry rejected this claim, citing the speed and distance discrepancies between the vessels.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Substantial Evidence:

   • The findings of administrative bodies, if based on substantial evidence, are binding on reviewing authorities. Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
   • The Philippine Coast Guard's decision was thorough and based on rational probative evidence, including the speed and distance of the vessels, which contradicted Captain Doruelo's claims.

2. Administrative Due Process:

   • Decisions must be based on evidence presented during the hearing or contained in the record and disclosed to the parties. The Ministry of National Defense erred in considering evidence of another sea collision not presented during the hearing.
   • If Captain Doruelo is liable for another sea mishap, his liability must be determined in separate proceedings.

3. Modification of Penalty:

   • The Court reinstated the original two-year suspension for Captain Doruelo, as the increased penalty was based on improper considerations.

Conclusion:

The Supreme Court dismissed the petition, upheld the factual findings of the Philippine Coast Guard, and reinstated the original two-year suspension for Captain Doruelo, emphasizing the importance of administrative due process and the need for decisions to be based on evidence presented during the hearing.