G.R. No. 238201 - Federal Land, Inc. vs. Northlander Real Estate and Development, Inc.

Case Digest (G.R. No. 238201)
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Facts:

Background and Contractual Relationship

On June 10, 1994, Maritime Factors Inc., a domestic manning agency, engaged Danilo R. Hindang on behalf of its foreign principal, Bahrain Marine Contracting/Panama, to work as a GP/Deckhand on board the Panamanian-registered M/T "Reya."
Danilo’s employment contract was valid for 12 months with a basic monthly salary of US$230.00.

Incident on Board and Discovery of the Body

On July 27, 1994, while the vessel was within the territorial jurisdiction of the Kingdom of Saudi Arabia, crew members forced open Danilo’s cabin door by removing the door lock screws using a screwdriver.
Upon forcing the door open, they discovered Danilo’s body inside his locker (wardrobe), found hanging by a strap around his neck in a kneeling position.

Medical Examinations and Conflicting Autopsy Reports

The body was turned over to the Saudi police and brought to Medical Examiner Dr. Ossman Abdel Hameed, who conducted an autopsy and concluded that the cause of death was suicide by hanging.
After repatriation to the Philippines, Danilo’s family requested a second autopsy by Dr. Maximo L. Reyes of the NBI, who determined the cause of death to be Asphyxia by strangulation, ligature, implying that somebody caused his death.
Dr. Reyes issued a certification on December 27, 1994, clearly indicating that the death resulted from asphyxia by strangulation.

Claim for Death Benefits and Pre-Trial Proceedings

On August 24, 1994, Bemvenido R. Hindang, Danilo’s brother, filed a claim for death compensation benefits under the POEA Standard Employment Contract governing Filipino seamen.
Efforts to settle the matter amicably failed, leading the Labor Arbiter (LA) to require submission of position papers by both parties.

Position Papers and Evidence Presented

Petitioner Maritime Factors Inc. submitted a position paper asserting that Danilo committed suicide, relying on:

A photocopy of a fax transmission of a purported 4-page medical report by Dr. Hameed, which stated suicide by hanging.
A written report dated September 21, 1994, by Danilo’s fellow crew members noting that the cabin door was locked and that Danilo was found hanging in his locker.

Respondent argued that:

The NBI autopsy report by Dr. Reyes clearly indicated death by asphyxia by strangulation.
The photocopy facsimile of Dr. Hameed’s report was unreliable and unverified as due execution or genuineness, being merely a copy transmitted from the foreign principal.

Decisions of the Labor Arbiter, NLRC, and Court of Appeals

On November 29, 1996, the Labor Arbiter rendered a decision ordering Maritime Factors Inc. (and/or its foreign employer) to pay US$50,000.00 as death benefits.

The LA based its decision on:

The credibility of the NBI autopsy report over the photocopied fax report.

ii. The lack of evidence that Danilo was suicidal, noting no proof of any mental instability or observed self-harming behavior.

The NLRC, on August 18, 1998, affirmed the LA decision in a resolution, a decision which was later upheld after a petition for reconsideration.
Maritime Factors Inc. petitioned the CA for certiorari under Rule 65, contesting the NLRC resolutions.
In its Decision dated November 28, 2001, the CA:

Denied petitioner’s petition, affirming that the NBI autopsy report and certification by Dr. Reyes prevailed over the disputed photocopy of Dr. Hameed’s report.
Rejected petitioner’s contentions regarding the reliability of the medical report and disregarded the alternative evidence submitted.

Petitioner’s Assignments of Error and Further Contentions

Petitioner contended that the CA erred in:

Disregarding the medical report of Dr. Hameed, which was based on an actual examination and ocular inspection.
Relying on speculations and conjectures rather than the factual evidence of the photocopied report.
Accepting respondent’s proof of relationship, as petitioner had already admitted the kinship in its Answer.

Petitioner further argued that:

The fax transmission, though a photocopy, should be granted legal effect.
Quasi-judicial bodies like the NLRC are not strictly bound by technical rules of evidence and procedure.

Issues:

Whether Danilo committed suicide during his term of employment or if his death resulted from asphyxia by strangulation, thereby making the death compensable under the POEA Standard Employment Contract.

The core factual dispute centers on the determination of the cause of Danilo’s death.
The evidentiary issue involves reconciling conflicting medical reports from Dr. Hameed and Dr. Reyes.

Whether the photocopy of the fax transmission of Dr. Hameed’s medical report should be admitted as evidence despite its technical deficiencies concerning genuineness and due execution.

The admissibility and reliability of the photocopy versus the independent NBI autopsy report are central to the resolution of the case.

Whether administrative and quasi-judicial bodies (such as the LA and NLRC) are bound by the same technical evidentiary rules as regular courts in reviewing cases involving death compensation for seamen.

Whether respondent is entitled to death benefits based on the evidence presented, and if the burden of proof effectively shifted to petitioner after the evidentiary submissions.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 238201)
Standard Advanced