Case Digest (G.R. No. 255802)
Facts:
One Shipping Corporation, G.R. No. 255802, October 12, 2022, the Supreme Court Second Division, Lopez, M., J., writing for the Court. Petitioner One Shipping Corporation is a domestic crewing and recruitment company; respondents are the Heirs of the late Ricardo R. Abarrientos, represented by Romana R. Abarrientos, who sought death benefits under the parties' Collective Bargaining Agreement (CBA) and the POEA Standard Employment Contract (POEA‑SEC).On August 24, 2013, petitioner hired Ricardo as Chief Officer aboard M/V "Dyna Crane" for a nine‑month contract; Ricardo was repatriated earlier and arrived in the Philippines in February 2014. On April 14, 2014 Ricardo signed an Affidavit of Receipt, Release, Waiver, and Quitclaim acknowledging receipt of his final salary and benefits. Ricardo was hospitalized on August 19, 2014; he was diagnosed with pancreatic cancer with metastasis and died on September 3, 2014.
Respondents filed a grievance and then, on March 2, 2018, a complaint before the Panel of Voluntary Arbitrators claiming death benefits under the IBF JSU/AMOSUP IMMAJ CBA and the POEA‑SEC, alleging Ricardo was medically repatriated or that his illness was work‑related due to shipboard stress, long hours, and alleged exposure to chemicals; they also alleged they made prior extrajudicial demands and received a denial on September 3, 2015.
Petitioner denied medical repatriation, stressed Ricardo finished his contract and surrendered a quitclaim, and pleaded prescription (claim filed beyond three years), absence of post‑employment medical examination, and lack of proof that death was work‑related. The Panel (2–1) granted respondents' claim in a Decision dated June 21, 2019 (later modified as to monetary award), ordering substantial death and related benefits. Member George A. Eduvala dissented at the Panel; the majority relied on respondents' allegations and computed prescription from the alleged denial on September 3, 2015.
Petitioner moved for reconsideration before the Panel (denied), then appealed to the Court of Appeals (CA). In a Decision dated October 30, 2020 the CA affirmed the Panel's award in to...(Pro-only)
Issues:
- Was respondents' claim for death benefits seasonably filed (i.e., did it fall within the three‑year prescriptive period)?
- Was Ricardo's death compensable under the CBA and the POEA‑SE...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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