Title
One Shipping Corporation vs. Heirs of the Late Ricardo R. Abarrientos
Case
G.R. No. 255802
Decision Date
Oct 12, 2022
Heirs claimed seafarer's death benefits alleging work-related illness; SC ruled claim barred by prescription and lack of evidence on compensability, awarding P100k financial assistance instead.
A

Case Digest (G.R. No. 255802)

Facts:

  • Background of the parties
    • Petitioner, One Shipping Corporation, is a domestic corporation engaged in crewing and recruitment of Filipino seafarers.
    • Respondents are the heirs of the late Ricardo R. Abarrientos, represented by Romana R. Abarrientos.
  • Employment and work details of Ricardo R. Abarrientos
    • Ricardo was hired by petitioner as Chief Officer aboard M/V "Dyna Crane" for a nine-month contract beginning August 24, 2013.
    • Ricardo was repatriated earlier than the contract end date on February 20, 2014.
    • Upon repatriation, Ricardo received his final salary and benefits, which he acknowledged in an Affidavit of Receipt, Release, Waiver, and Quitclaim dated April 14, 2014.
  • Ricardo's illness and death
    • On August 19, 2014, about six months after repatriation, Ricardo was hospitalized in Cagayan de Oro and diagnosed with pancreatic cancer, which metastasized to his liver and lungs.
    • He died on September 3, 2014, due to liver cirrhosis.
  • Respondents' claim for death benefits
    • On March 2, 2018, respondents filed a complaint claiming death benefits under the IBF JSU/AMOSUP a IMMAJ Collective Bargaining Agreement (CBA).
    • They alleged Ricardo's death was work-related, citing his exposure to harsh sea conditions, long working hours, and stress from being away from family.
    • They recounted incidents including December 2013 where Ricardo experienced dizziness and stomach upset during heavy weather but was denied immediate medical assistance.
    • They claim petitioner refused to provide post-employment medical examination upon Ricardo's arrival.
    • Respondents demanded death benefits multiple times starting two months after Ricardo's death but were continuously denied.
  • Petitioner's position
    • Petitioner denied medical repatriation, asserting Ricardo's contract was terminated due to sale of the vessel.
    • Ricardo had no medical complaints on board and did not undergo post-employment medical examination.
    • Petitioner claimed no liability for death benefits, arguing the claim was prescribed and death was neither work-related nor during employment.
  • Proceedings before the Panel of Voluntary Arbitrators
    • The Panel, with a 2-1 vote, ruled in favor of respondents, awarding death benefits, burial expenses, minor child's benefits, and attorney's fees.
    • The Panel ruled that the cause of action accrued on September 3, 2015, when petitioner allegedly denied death benefits, thus filing the complaint on March 2, 2018 was within the three-year prescriptive period.
    • The Panel disregarded Ricardo's failure to undergo post-employment medical examination, accepting respondents' allegation of refusal.
    • The Panel found Ricardo's death was work-related, citing his exposure to chemicals and harsh working conditions as causing his illness and death.
  • Court of Appeals (CA) ruling
    • The CA affirmed the Panel's Decision and denied petitioner's motion for reconsideration.
  • Petition for Review on Certiorari
    • Petitioner contends the rulings are based on speculation, lack substantial evidence, and misapprehension of facts.
    • Petitioner challenges the reckoning of prescription, existence of medical repatriation, and compensability of Ricardo's death.

Issues:

  • Whether the respondents' claim for death benefits was timely filed or barred by prescription.
  • Whether Ricardo's death was compensable under the Collective Bargaining Agreement and the 2010 Philippine Overseas Employment Agency Standard Employment Contract (POEA-SEC).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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