Case Summary (G.R. No. 190161)
The Facts
Nancing was employed by Magsaysay on July 14, 2006, and was declared fit for duty after a medical examination. He suffered an accident on February 20, 2007, while working aboard the vessel M/V North Sea, resulting in injuries leading to a diagnosis of bilateral closed traumatic hemothorax. Following a period of medical treatment, he was repatriated to Manila where he ultimately died on April 25, 2007. The death certificate indicated acute respiratory failure as the immediate cause of death, with lung metastasis and bone cancer as underlying causes.
Initial Complaint
On May 23, 2007, Anita filed a complaint against the respondents for death benefits, claiming the accident had caused the complications leading to Nancing's death. The respondents denied liability, attributing Nancing's death to lung cancer, contending that it was not a work-related illness.
Labor Arbiter's Ruling
On December 27, 2007, the Labor Arbiter ruled in favor of the petitioners, awarding death benefits amounting to $72,000, which included death compensation for the minor children, burial expenses, and damages. The Labor Arbiter determined that the injury sustained during Nancing's employment was a contributing factor to his eventual demise.
NLRC Ruling
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's ruling on April 30, 2008, concluding that Nancing's death was linked to the work-related injury. However, the NLRC found that Nancing's contract technically ended upon his medical repatriation, which influenced the determination of benefits.
Court of Appeals Ruling
The Court of Appeals, in a decision dated May 19, 2009, found the NLRC's ruling to contain grave abuse of discretion, asserting that sorcerers’ death after contract termination was non-compensable, irrespective of work-related factors that led to his illness. The petitioners' motion for reconsideration was denied on October 30, 2009.
The Core Legal Issue
The primary issue for resolution was whether the Court of Appeals committed reversible error by dismissing the compensation claim after Nancing's employment was deemed terminated due to his medical repatriation. The petitioners argued that the work-related accident triggered a series of health complications, including his death.
The Court's Ruling
The Supreme Court clarified the governing provisions of the POEA regarding compensability of death benefits, emphasizing two requirements: the death must be work-related and must occur during the employment term. The Court determined that Nancing’s injury satisfied the work-related requirement, as it significantly contributed to his health deterioration and subsequent death.
Exception to Employment Termi
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Background of the Case
- The case involves a petition for review on certiorari filed by Anita N. Canuel and her minor children against Magsaysay Maritime Corporation, Eduardo U. Manese, and Kotani Shipmanagement Limited.
- The petition contests the Decision dated May 19, 2009, and the Resolution dated October 30, 2009, of the Court of Appeals (CA), which dismissed the petitioners' complaint for death benefits.
Factual Summary
- Nancing R. Canuel was employed as a Third Assistant Engineer by Magsaysay Maritime Corporation on July 14, 2006, for a twelve-month contract with a monthly salary of US$640.00.
- After a pre-employment medical examination, he was deemed fit for work and joined the vessel M/V North Sea on July 19, 2006.
- On February 20, 2007, Nancing suffered an accident while on duty, resulting in injuries that led to a diagnosis of bilateral closed traumatic hemothorax.
- He was repatriated on March 24, 2007, and admitted to a hospital in Manila. Due to complications, he was placed in intensive care and died on April 25, 2007, with the death certificate indicating acute respiratory failure as the immediate cause and lung metastasis with bone cancer as the underlying cause.
- Anita N. Canuel filed a complaint for death benefits and other compensations against the respondents on May 23, 2007.
Legal Proceedings
Labor Arbiter (LA) Ruling
- The Labor Arbiter ruled in favor of the petitioners, awarding a total sum of US$72,000.00, including death benefits, death compensation for minor children, burial expenses, moral and exemplary damages, and attorney’s fees.
- The LA concluded that Nancing’s