Case Digest (G.R. No. 244361)
Facts:
The Heirs of Reynaldo A. Andag, namely Veneranda B. Andag, Jaymari B. Andag, Honey Grace B. Andag and Kim Philip B. Andag, represented by their attorney-in-fact, Veneranda B. Andag, Petitioners, vs. DMC Construction Equipment Resources, Inc., Jorge A. Consunji, President, and Agustine B. Gonzalez, Area Manager, Respondents, G.R. No. 244361, July 13, 2020, Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court.On July 16, 2012, Reynaldo A. Andag was employed by DMC Construction Equipment Resources, Inc. (DMCI) as Second Mate aboard the tugboat MIT Alexander Paul. On October 18, 2013, while the tugboat was towing an overloaded barge, a recoiling rope struck Reynaldo and he was thrown against iron bars; he was rushed to the hospital and pronounced dead on arrival. Afterwards, DMCI reportedly offered the heirs P200,000 as compensation conditioned on their signing a waiver and quitclaim; petitioners refused and their demand letter was ignored.
Petitioners filed a complaint with the National Labor Relations Commission (NLRC), Regional Arbitration Branch No. VI, Iloilo City, seeking: (a) death compensation/benefits; (b) actual, moral and exemplary damages and attorney’s fees for alleged employer negligence; and (c) other monetary claims due Reynaldo (holiday pay, service incentive leave, 13th-month pay). DMCI answered that death benefits lay with the State Insurance Fund (SSS), that the P200,000 represented accidental death insurance proceeds it had secured for employees, and that it had already paid Reynaldo’s wages as shown by payslips.
The Labor Arbiter dismissed the complaint for lack of cause of action in a Decision dated September 28, 2016, agreeing that death benefits should be sought from the SSS, finding no proof of employer liability for Reynaldo’s death, denying moral and exemplary damages, and ruling that wages/benefits had been paid. Petitioners appealed to the NLRC.
In a Decision dated January 30, 2017, the NLRC affirmed the Labor Arbiter with modification: it held that (1) because Reynaldo was an inter-island seaman working in domestic waters and his employment lacked a POEA-standard contract, death benefits are governed by the Labor Code and are payable by the State Insurance Fund (SSS); (2) the claim for damages for alleged employer negligence is a tort cognizable by the regular courts, not by labor tribunals; and (3) the P200,000 accidental death insurance proceeds, having been released to DMCI but conditioned upon a quitclaim, must be turned over to petitioners without condition. Petitioners’ motion for reconsideration before the NLRC was denied in a March 23, 2017 Resolution.
Petitioners filed a petition for certiorari appealing to the Court of Appeals (CA). In a Decision dated February 28, 2018, the CA in CA-G.R. CEB-SP No. 10946, penned by Associate Justice Marilyn B. Lagura-Yap, upheld the NLRC’s rulings that (a) petitioners’ damages claim was a tort co...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly find that the NLRC did not commit grave abuse of discretion in its rulings?
- Was DMCI liable to pay death compensation/benefits to petitioners, or are such benefits payable exclusively by the State Insurance Fund (SSS) under the Labor Code?
- Was the petitioners’ cause of action for damages grounded on employer negligence cognizable by the labor tr...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)