Title
Eastern Shipping Lines, Inc. vs. Philippine Overseas Employment Administration
Case
G.R. No. 85061
Decision Date
Aug 16, 1991
Urbiztondo, employed by Eastern Shipping Lines, died during an ongoing voyage; POEA awarded benefits to heirs, upheld jurisdiction and validity of its regulations despite employer's procedural objections.

Case Digest (G.R. No. 85061)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Francisco Urbiztondo, an employee of Eastern Shipping Lines, was hired for the duration of the voyage of the vessel Eastern Galaxy, which commenced on November 9, 1985.
    • Urbiztondo was disembarked on December 13, 1985, for medical treatment; however, there is no indication in the record that the voyage had ended at the time of his death.
  • Claim for Benefits
    • The petitioner (Eastern Shipping Lines, Inc.) challenged the decision of the Philippine Overseas Employment Administration (POEA) which had awarded death and burial benefits to the private respondents.
    • The awarded benefits included P180,000.00 as death compensation and P18,000.00 for burial allowances, totaling P198,000.00 over and above the benefits provided under Philippine laws.
  • Jurisdictional and Regulatory Issues Raised
    • The petitioner contended that the POEA did not have jurisdiction over the employee’s claim, arguing that such claim should instead be filed with the Social Security System and charged to the State Insurance Fund.
    • The defense that the employee’s voyage had ended prior to his death was not raised in the respondent’s answer, thus leaving the factual record unchallenged on this matter.
  • Applicable Rules and Regulations
    • The case revolves around the application of Section D, Part II of the POEA Standard Format, which was amended by Memorandum Circular No. 2 and took effect on February 1, 1984.
    • This administrative regulation, under which the benefits were awarded, was later upheld by the Court as valid and binding.
  • Prior Rulings and Evidence
    • The Court relied on the earlier decision in Eastern Shipping Lines v. POEA, where it was held that under Section 4(a) of Executive Order No. 797, POEA had original and exclusive jurisdiction over cases involving employee-employer relations for Filipino contract workers, including seamen.
    • The evidence substantiating the factual findings, including documents submitted by the petitioner, was found sufficient and not arbitrary.

Issues:

  • Jurisdiction of the POEA
    • Whether the Philippine Overseas Employment Administration possesses the jurisdiction over the employee’s claim for death and burial benefits, as opposed to the Social Security System or the State Insurance Fund.
    • Whether the petitioner’s argument challenging the POEA’s jurisdiction is valid in light of the established executive order and prior case law.
  • Validity of the Administrative Regulation
    • Whether Memorandum Circular No. 2, which prescribes the payment of death and burial benefits, is a valid exercise of administrative power under the delegation made by Executive Order No. 797.
    • Whether the administrative procedure followed in awarding the benefits meets the evidentiary requirements despite alleged lapses in strict adherence to technical rules of procedure.
  • Procedural Objections Raised by the Petitioner
    • Whether the procedural objections, particularly the failure to resolve the motion to dismiss before the case was decided on the merits, are substantial enough to invalidate the decision.
    • Whether the observed procedural irregularities undermine the evidentiary basis for the factual findings of the POEA.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
Unlock Full Case Digest

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.

About Privacy Terms