Case Digest (G.R. No. 166580)
Facts:
- Prudential Shipping and Management Corporation (PSMC) and Zenith Shipping Investment, Ltd. (ZSIL) are the petitioners.
- Emerlinda A. Sta. Rita and Rene A. Sta. Rita are the respondents.
- Virgilio C. Sta. Rita was hired as an oiler on May 5, 1999, with a 12-month contract and a monthly salary of US$335.00.
- He underwent a pre-employment medical examination and was deemed fit for sea duty, despite a mild left axis deviation noted in his ECG.
- Virgilio boarded the M/V Gulfwind on May 20, 1999, but fell ill during his service.
- Diagnosed with an umbilical hernia on March 3, 2000, in New Orleans, he was advised to avoid heavy lifting and undergo surgery.
- He was repatriated to Manila on March 8, 2000, and diagnosed with a peri-umbilical mass due to ascites.
- After surgery on March 24, 2000, he was discharged on March 29, 2000, and signed a "Certificate of Fitness for Work" on June 20, 2000.
- Virgilio was admitted to the Philippine General Hospital on February 13, 2001, with severe health issues and died on March 18, 2001.
- His death was attributed to cardiopulmonary arrest due to metabolic acidosis and hepatocellular carcinoma.
- Emerlinda and Rene filed a complaint for death compensation and other claims on June 5, 2001.
- The Labor Arbiter ruled in favor of the respondents, but the NLRC reversed this decision, leading to an appeal to the Court of Appeals, which reinstated the Labor Arbiter's ruling.
- The petitioners subsequently filed a petition for review before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, reversing the Court of Appeals' decision and reinstating the NLRC ruling.
- The Court held that the respondents were not entitled to death benefits as Virgilio's employment had already been terminated at ...(Unlock)
Ratio:
- The Supreme Court stated that under the POEA Standard Employment Contract, death benefits are payable only if the seafarer dies during the term of his contract.
- Virgilio's employment was deemed terminated upon his repatriation on March 8, 2000, and he...continue reading
Case Digest (G.R. No. 166580)
Facts:
The case involves Prudential Shipping and Management Corporation and Zenith Shipping Investment, Ltd. as petitioners, and Emerlinda A. Sta. Rita, for herself and on behalf of Rene A. Sta. Rita, as respondents. The events leading to the case began on May 5, 1999, when Zenith Shipping Investment, Ltd. (ZSIL), through Prudential Shipping and Management Corporation (PSMC), hired Virgilio C. Sta. Rita as an oiler on board the M/V Gulfwind. His employment contract was for 12 months, with a basic monthly salary of US$335.00, a 48-hour work week, overtime pay of US$2.01 per hour, and a monthly vacation leave of 4 days. During his pre-employment medical examination, he was deemed fit for sea duty, although an electrocardiogram (ECG) indicated a mild left axis deviation. Virgilio boarded the ship on May 20, 1999, but fell ill while on board. On March 3, 2000, he was diagnosed with an umbilical hernia in New Orleans, Louisiana, and was advised to avoid heavy lifting and to undergo surgery. He was repatriated to Manila on March 8, 2000, where he was evaluated by company-designated physicians and found to have a peri-umbilical mass due to ascites. He underwent umbilical herniorrhaphy on March 24, 2000, and was later diagnosed with liver cirrhosis. After a successful operation, he was discharged on March 29, 2000, and signed a "Certificate of Fitness for Work" on June 20, 2000, releasing his employer from all claims. However, on February 13, 2001, he was admitted to the Philippine General Hospital (PGH) with severe health issues, including liver cirrhosis and pleural effusion, and ...