Case Digest (G.R. No. 241844)
Facts:
Ethyl Huiso Ebal & her minor child, on behalf of the deceased Edville Cliano Beltran v. Thenamaris Philippines, Inc., et al., G.R. No. 241844 (Formerly UDK 16236), and Thenamaris Philippines, Inc., et al. v. Ju-Ann Beltran and Jhun Ville Beltran, G.R. No. 257584, November 29, 2023, Supreme Court Third Division, Singh, J., writing for the Court.The disputes arise from competing claims for statutory death benefits after Edville C. Beltran died on board the M/T Seacross on October 20, 2015, six days after boarding pursuant to a seven‑month employment contract. Edville was hired by Thenamaris Philippines, Inc. for foreign principal Narcissus Enterprises S.A. as Third Engineer. A pre‑employment medical examination (PEME) had declared him fit for sea duty. He developed symptoms beginning October 19, 2015 and was pronounced dead on board the following morning. An initial NBI post‑mortem reported cardio‑respiratory arrest (etiology to be determined); a later autopsy characterized the cause as pneumonia.
Two sets of claimants filed before the NLRC: (1) petitioners in G.R. No. 241844 — Edville’s illegitimate child Travez (through mother Ethyl) — filed a complaint for death benefits (NLRC RAB No. NCR (M)-03-03109-16), and respondents then filed a cross‑complaint against the legitimate wife and child (NLRC RAB No. NCR (M)-04-03961-16); and (2) petitioners in G.R. No. 257584 — the wife Ju‑Ann and legitimate child Jhun — filed a separate complaint in Dumaguete (NLRC RAB No. VII-06-0002-16-D). The Labor Arbiter in Manila (Sept. 2, 2016) granted Travez’s claim and awarded death benefits and fees; a different Labor Arbiter in Dumaguete (Nov. 28, 2016) dismissed the wife/child claim for insufficiency of evidence.
On appeal the NLRC rendered conflicting results: in G.R. No. 241844 (Jan. 20, 2017) the NLRC First Division reversed the Labor Arbiter and dismissed Travez’s complaint for lack of merit; in G.R. No. 257584 (Mar. 6, 2017) the NLRC Seventh Division vacated the Dumaguete Labor Arbiter and found the death work‑related, awarding US$61,700 aggregate to Ju‑Ann and Jhun. Both sides sought certiorari before the Court of Appeals; the CA denied relief to Ethyl and Travez (Feb. 14, 2018) and denied Thenamaris’s petition in G.R. No. 257584 (July 23, 2020), thereby affirming the NLRC vindicating Ju‑Ann and Jhun.
Both sets of aggrieved parties filed Rule 45 petitions before the Supreme Court. The Court’s Second Division initially denied the petition in G.R. No. 257584 (Oct. 19, 2022). Thenam...(Subscriber-Only)
Issues:
- Under Rule 45, may the Court review the NLRC’s factual findings in these petitions?
- Was there substantial evidence that pneumonia, the cause of Edville Beltran’s death, was work‑related and therefore compensable under the ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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