G.R. No. 202859 - New Filipino Maritime Agencies, Inc. vs. Datayan

New Filipino Maritime Agencies, Inc. (NFMA), along with Taiyo Nippon Kisen Co., Ltd. and Angelina T. Rivera, are the petitioners.
Vincent H. Datayan, as the heir of Simon Vincent H. Datayan II, is the respondent.
Simon Vincent Datayan II was employed as a deck cadet on board the vessel Corona Infinity.
His employment term was for nine months with a basic monthly salary of US$235.00, and he had successfully undergone a pre-employment medical examination (PEME), being declared fit for sea duties.

Simon boarded the vessel on August 17, 2007, and assumed his duties as a deck cadet.
On December 30, 2007, an emergency fire drill was conducted at approximately 12:40 a.m., during which a crew meeting followed for performance evaluation.
It was during or immediately after this drill, at about 1:25 a.m., that Simon was observed jumping overboard.
A search-and-rescue operation was immediately launched, but Simon was later declared missing and presumed dead.

Vincent H. Datayan, acting as the claimant for death benefits, alleged that Simon’s death, occurring during his employment contract, should render him eligible for compensation under the applicable collective bargaining agreement (CBA) and the Philippine Overseas Employment Administration (POEA) Standard Employment Contract (SEC).
The respondent argued that since death benefits are generally payable if the death is work-related, his claim should be honored.
However, petitioners contended that Simon’s death was the result of his own willful act (suicide) and that, accordingly, no death benefits are due under the terms of the POEA SEC.

On May 31, 2010, the Labor Arbiter (LA) dismissed the complaint for death benefits on the grounds that evidence established that Simon committed suicide.
The National Labor Relations Commission (NLRC) subsequently affirmed the LA’s decision on appeal, giving substantial weight to the Master’s Report and the suicide note as evidence of suicide.
The Court of Appeals (CA), on February 22, 2012, reversed and set aside the decisions of the NLRC and the LA, holding that there was insufficient evidence to conclude that Simon committed suicide, and ordered the payment of death benefits along with additional damages, attorney’s fees, and legal interest.
A motion for reconsideration before the CA was denied on July 24, 2012.
Petitioners then assailed the CA’s decision in the Petition for Review on Certiorari before the Supreme Court.

The Master’s Report, which detailed the events before, during, and after the drill, including the observation of Simon jumping overboard by a crew member (Raymond Ocleasa).
The Investigation Report and the Statement of Facts, which provided accounts from other crew members and described Simon’s behavior and circumstances.
A suicide note allegedly written by Simon, which the LA and the NLRC found probative in establishing that his death was a result of his own willful act.
Discrepancies noted by the CA regarding the authenticity and probative value of the suicide note and the lack of positive testimony by the Master regarding Simon’s suicide.

Whether the Court of Appeals was correct in finding that the National Labor Relations Commission (NLRC) had gravely abused its discretion in dismissing Vincent H. Datayan’s claim for death benefits based on the conclusion that Simon committed suicide.
Whether the evidence was sufficient to show that Simon’s death was the result of his own deliberate act, thereby exempting the petitioners from the payment of death benefits under the applicable POEA SEC.