G.R. No. 143313 - Pandiman Phil. Inc. vs. Marine Manning Management Corp.

Benito Singhid was employed as chief cook on board the vessel MV Sun Richie Five by Fullwin Maritime Limited.
His employment was facilitated through the local agent, Marine Manning Management Corporation (MMMC), under a fixed-term contract of twelve (12) months.

The vessel and its crew were insured by Ocean Marine Mutual Insurance Association Limited (OMMIAL), a member of a Protection and Indemnity (P&I) Club.
OMMIAL conducted its operations in the Philippines through its local correspondent, petitioner Pandiman Philippines, Inc. (PPI).

While en route from Ho Chih Minh City, Vietnam to Shanghai, China, Benito suffered a fatal heart attack and died on June 24, 1997.
After his remains were flown back to the Philippines and interred, his widow, Rosita Singhid, filed a claim for death benefits.

MMMC, having received the claim from Rosita, referred her to PPI, which approved the claim and recommended a payment of US$79,000.00.
Despite the approval, the claim remained unpaid, prompting Rosita to seek legal recourse.

Rosita filed a complaint with the Labor Arbiter for recovery of death benefits, moral and exemplary damages, and attorney’s fees.
The Labor Arbiter, in a decision dated November 16, 1998, awarded death benefits and additional awards to Rosita and her minor children but dismissed the claim against PPI.
On appeal, the National Labor Relations Commission (NLRC) set aside the Labor Arbiter’s decision, absolving MMMC from liability and holding PPI and OMMIAL jointly responsible for the death benefits.

Petitioner PPI sought review through a petition for certiorari filed with the Court of Appeals (CA-G.R. SP No. 53648).
The Court of Appeals dismissed the petition on February 17, 2000, affirming the NLRC decision. A motion for reconsideration filed by PPI was subsequently denied on May 16, 2000.

PPI contended that it was merely acting as a local correspondent and not as an insurance agent under Section 300 of the Insurance Code.
PPI further argued that due process was violated by relying on factual findings it deemed erroneous and that it should not be held liable for death benefit claims under an insurance contract to which it was not a party.

The factual record clearly showed that Benito was employed by Fullwin through MMMC at the time of his death.
PPI maintained that MMMC and Fullwin should be held jointly and solidarily liable for the claimed death benefits, given MMMC’s undertaking under the Rules and Regulations Governing Overseas Employment (1991).

Whether PPI can be classified as an insurance agent under Section 300 of the Insurance Code based on its role as a local correspondent.
Whether the actions taken by PPI in processing the death claim amount to solicitation or negotiation sufficient to impose agency liabilities.

Whether MMMC and Fullwin, as parties to the employment contract with Benito, are jointly and solidarily liable for the death benefits claimed by Rosita Singhid.
Whether exempting MMMC and Fullwin from liability, as done by the NLRC and affirmed by the Court of Appeals, is tenable in light of the contractual obligations and applicable regulations.