G.R. No. 167678 - Southeastern Shipping vs. Navarra, Jr.

Southeastern Shipping, on behalf of its foreign principal, Southeastern Shipping Group, Ltd., hired Federico U. Navarra, Jr. to work on board the vessel "George McLeod."
Federico executed 10 successive and separate employment contracts covering the period from October 5, 1995 to March 30, 1998.
His latest contract, approved by the Philippine Overseas Employment Administration (POEA) on January 21, 1998, was initially for 56 days with an extension option for another 56 days.
He served first as a roustabout and then as a motorman during subsequent contracts.

On March 6, 1998, while on board, Federico complained of a sore throat, intermittent fever with chills, and a developing soft mass on the left side of his neck; he was given medication.
Federico returned to the Philippines on March 30, 1998.
On April 21, 1998, tests on an excised specimen from his lymph node were negative for malignancy.
On June 4, 1998, he was diagnosed with Hodgkin’s Lymphoma, Nodular Sclerosing Type (Hodgkin’s Disease) at the Philippine General Hospital, a diagnosis which was confirmed on June 8, 1998, at the Medical Center Manila.

On September 6, 1999, Federico filed a complaint with the arbitration branch of the National Labor Relations Commission (NLRC) seeking various benefits: disability benefits (later converted into death benefits), loss of earning capacity, moral and exemplary damages, and attorney’s fees.
During the pendency of the claim, Federico died on April 29, 2000.
His widow, Evelyn, substituted him in the complaint on both her own behalf and for their three children.

Labor Arbiter Ermita T. Abrasaldo-Cuyuca dismissed Federico’s complaint on the ground that “Hodgkin’s Lymphoma is not one of the occupational or compensable diseases or the exact cause is not known.”
The decision disposed of the case as lacking merit.

The NLRC reversed the Labor Arbiter’s decision.
It ordered the respondents (Southeastern Shipping/Southeastern Shipping Group Ltd.) to pay death compensation amounting to US$50,000; minors’ allowances (US$7,000 for each of three minor children); burial expenses of US$1,000; plus an additional 10% for attorney’s fees, amounting to a total of US$72,000 plus fees.

The CA upheld that the claim for benefits had not prescribed, even though the complaint was filed more than one year after Federico’s return to the Philippines.
It held that despite Federico’s death occurring 17 months after his contract expired, his heirs could still claim benefits because the cause of his illness appeared linked to his employment.
The CA affirmed the NLRC decision in its entirety.

Contended that the factual findings of the CA lacked sufficient evidence, particularly citing the medical report of Dr. Salim Marangat Paul, which indicated an Acute Respiratory Tract Infection rather than Hodgkin’s Disease.
Claimed that Federico’s return to the Philippines on March 30, 1998, was due to the completion of his contract, not because of a worsening medical condition.
Argued that the filing was tardy, meaning the claim had prescribed given the one-year limit purported in Section 28 of the Standard Employment Contract for Seafarers.
Maintained that Federico did not die during the effective period of his employment contract and thus was not entitled to death benefits.

Argued that the prescription period for seafarer claims should be governed by the Labor Code’s three-year rule from the time the cause of action accrued.
Asserted that in case of conflict between the POEA Contract and the law (Labor Code), the law prevails.
Claimed that Federico contracted the illness while on board, thereby making it compensable under the terms of the Standard Employment Contract for Seafarers.

Whether the claim for benefits prescribed despite the complaint being filed beyond the contractual one-year period, and if the prescription should instead be determined under Article 291 of the Labor Code providing a three-year period.
Whether Hodgkin’s Disease, as diagnosed and later determined, qualifies as a compensable illness under the Standard Employment Contract for Seafarers.
Whether petitioners can be held liable for death benefits given that Federico’s death occurred after the termination of his employment contract and without sufficient proof linking the cause of death to his stint on board.