Case Digest (G.R. No. 77828)
Facts:
The case concerns a petition for certiorari and prohibition filed by Eastern Shipping Lines, Inc. (Eastern) against the Philippine Overseas Employment Administration (POEA), Secretary of Labor and Employment, Hearing Officer Cheryl Ampil, and Ma. Lourdes A. Zaragoza. The controversy originated from the claim of Ma. Lourdes A. Zaragoza for death benefits following the death of her husband, Manuel Zaragoza, who was employed as Chief Engineer of the M/V Eastern Meteor. Manuel had been employed by Eastern since 1973 and died on September 18, 1983, while in Kakogawa, Japan, as a result of myocardial infarction, as stated in a death certificate issued by a local doctor. Following his death, Ma. Zaragoza filed a formal complaint on December 17, 1985, with the POEA after Eastern allegedly refused to honor her claim for gratuity associated with her husband's death. She claimed a total of P100,000.00 in death benefits, as mandated by the Memorandum Circular No. 71 issued by the Natio
Case Digest (G.R. No. 77828)
Facts:
- Parties and Employment Background
- Petitioner: Eastern Shipping Lines, Inc. (“Eastern”), a shipping company engaged in operating ocean-going vessels.
- Private Respondent: Ma. Lourdes A. Zaragoza, the widow of Manuel Zaragoza, who was an employee of Eastern.
- Employment Relationship:
- Manuel Zaragoza had been employed by Eastern since 1973, serving as an engineer and later as Chief Engineer.
- At the time of his death, he was serving on board the M/V Eastern Meteor.
- Circumstances of Death
- Date and Place of Death:
- Manuel Zaragoza died on 18 September 1983 while in Kakogawa, Japan.
- At the time, he was working as Chief Engineer of the M/V Eastern Meteor.
- Death Certification:
- A Death Certificate issued by Dr. Masayuki Inoue of Kakogawa Hospital stated that the cause of death was “myocardial infarction.”
- Claim for Death Benefits
- Complaint Filing:
- On 17 December 1985, Mrs. Zaragoza filed a formal complaint with the Philippine Overseas Employment Administration (POEA) (Case No. L-86-01-026).
- Relief Sought by Mrs. Zaragoza:
- Death benefits of P100,000.00 based on the NSB Memorandum Circular No. 71 of 18 November 1981 issued by the former National Seamen Board.
- Additional claims for moral damages amounting to P50,000.00 and attorney’s fees.
- Eastern’s Response and Prior Payments
- Eastern’s Answer:
- Denied any additional liability by stating that the company had already paid P12,000.00 as a cash benefit and P5,000.00 for funeral expenses.
- Asserted that no cause of action existed beyond these amounts.
- Jurisdictional Argument:
- Eastern contended that it was not an “overseas employer” and claimed that the complaint should have been filed with the Social Security System rather than with POEA.
- Administrative and Procedural Developments
- POEA Decision:
- On 19 March 1987, POEA rendered a Decision ordering Eastern to pay P88,000.00 as the unpaid balance of death benefits.
- The claim for moral damages was dismissed due to lack of jurisdiction.
- Subsequent Judicial Actions:
- Eastern directly petitioned the Supreme Court for Certiorari and Prohibition challenging the POEA decision.
- A Temporary Restraining Order was issued on 8 April 1987.
- A preliminary issue regarding non-exhaustion of administrative remedies was raised by the Solicitor General; however, the Court considered that the questions raised were essentially legal in nature.
- Regulatory and Factual Context
- Applicable Legal Framework:
- Executive Order No. 797 (promulgated 1 May 1982) abolished the former National Seamen Board and conferred jurisdiction on the POEA over overseas employment matters.
- NSB Memorandum Circular No. 71 specified compensatory benefits for seamen in cases of total and permanent disability or death.
- Vessel Registration and Employment Conditions:
- The M/V Eastern Meteor was registered with both the Philippine Coast Guard and the Ministerio de Hacienda y Tesoro of the Republic of Panama.
- Despite dual registration, the vessel’s operations as an ocean-going vessel outside Philippine waters were central to determining the applicable benefits scheme.
- Eastern’s submission of its shipping articles to POEA underscored its recognition of the administrator’s jurisdiction over its overseas employment affairs.
Issues:
- Jurisdiction over the Claim
- Does POEA have original and exclusive jurisdiction over cases involving employment that occurs overseas, as contended by Executive Order No. 797 and the POEA Rules and Regulations?
- Is the complaint properly filed with POEA instead of with another agency such as the Social Security System?
- Classification of Employment
- Can Eastern Shipping Lines, Inc. be considered an “overseas employer” given that Manuel Zaragoza was employed on an ocean-going vessel operating outside Philippine territorial waters?
- Interpretation and Applicability of NSB Memorandum Circular No. 71
- Does NSB Memorandum Circular No. 71 apply to the case, particularly regarding the payment of death benefits for a master/Chief Engineer?
- How does the dual registration of the M/V Eastern Meteor (Philippine and Panamanian) affect the applicability of the benefits scheme provided in the memorandum?
- Constitutional and Legislative Validity
- Is the exercise of quasi-legislative power through NSB Memorandum Circular No. 71 constitutionally valid, in view of concerns regarding non-delegation of legislative power?
- Determination of the Benefit Amount
- What is the correct computation of the death benefits due to Mrs. Zaragoza under the applicable regulatory scheme?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)