Case Digest (G.R. No. 191740)
Facts:
The case involves Susana R. Sy as the petitioner and Philippine Transmarine Carriers, Inc. and SSC Ship Management Pte. Ltd. as the respondents. On June 23, 2005, Alfonso N. Sy (AB Sy) was employed by Philippine Transmarine Carriers, Inc. for its foreign principal, SSC Ship Management Pte. Ltd., as an Able Seaman (AB) on board the vessel M/V Chekiang. His employment contract stipulated a duration of ten months with a basic monthly salary of US$512.00. The contract incorporated the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC), which included standard provisions for Filipino seafarers.
On October 1, 2005, while the vessel was docked at the Port of Jakarta, Indonesia, AB Sy went on shore leave at approximately 1:00 PM. Later that evening, at around 7:25 PM, the vessel's agent was informed by local police that a crew member had died ashore. By 8:50 PM, AB Sy's body was confirmed at Cipto Mangunkusumo Hospital. Initial investigat...
Case Digest (G.R. No. 191740)
Facts:
Employment Contract and Shore Leave
Alfonso N. Sy (Sy) was employed as an Able Seaman (AB) by respondent Philippine Transmarine Carriers Inc. on behalf of its foreign principal, SSC Ship Management Pte. Ltd. His employment contract included the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC), which governed his employment. On October 1, 2005, while on shore leave in Jakarta, Indonesia, Sy died by drowning.
Circumstances of Death
Sy went on shore leave at 1300 hours and was later found dead at 1830 hours. The local police reported that Sy had stopped a motorcycle driver to urinate at a riverside and subsequently drowned. A forensic autopsy confirmed death by drowning, with traces of alcohol (20mg%) in his urine. The National Bureau of Investigation (NBI) in the Philippines also confirmed the cause of death as asphyxia by drowning.
Claim for Death Benefits
Sy's widow, Susana R. Sy, demanded death benefits and compensation from the respondents. The respondents denied the claim, arguing that Sy's death occurred during shore leave and was not work-related. Susana filed a complaint for death benefits, burial assistance, moral and exemplary damages, and attorney's fees.
Labor Arbiter and NLRC Rulings
The Labor Arbiter (LA) ruled in favor of Susana, awarding $50,000 in death benefits and $1,000 in burial expenses. The National Labor Relations Commission (NLRC) affirmed the LA's decision but added attorney's fees equivalent to 10% of the total monetary award.
Court of Appeals Decision
The Court of Appeals (CA) reversed the NLRC, ruling that Sy's death was not work-related. The CA held that Sy was on shore leave and not performing any work-related functions at the time of his death. The CA also ordered Susana to return the amount previously paid by the respondents.
Issue:
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Ruling:
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Ratio:
Work-Relatedness Requirement
Under Section 20(A) of the POEA Standard Contract, death benefits are only payable if the death is work-related and occurs during the term of the employment contract. Work-relatedness requires a causal connection between the death and the seafarer's employment.Shore Leave Not Work-Related
Shore leave is considered a personal activity and not part of the seafarer's duties. Sy's death occurred while he was on shore leave and was not performing any act related to his employment. Therefore, his death cannot be deemed work-related.Burden of Proof
The petitioner failed to provide substantial evidence establishing a connection between Sy's death and his employment. The presence of alcohol in Sy's urine suggested he was engaged in a personal activity, further negating the claim of work-relatedness.No Compensation for Non-Work-Related Death
The Court emphasized that while labor contracts are imbued with public interest, death benefits are only payable if the death is work-related. In this case, the evidence did not support such a finding.
Conclusion:
The Court upheld the CA's decision, ruling that Sy's death was not work-related and thus not compensable under the POEA Standard Contract. The petitioner was ordered to return the amount previously paid by the respondents.