Case Summary (G.R. No. 85061)
Factual Background and Procedural History
Francisco Urbiztondo was employed for the duration of the voyage of the Eastern Galaxy, commencing on November 9, 1985. He was disembarked for medical treatment on December 13, 1985, and he subsequently died. The core issue is whether the POEA had jurisdiction over the claim for benefits, which the petitioner contested, arguing that such claims should have been addressed to the Social Security System and charged to the State Insurance Fund. The POEA ruled in favor of Urbiztondo's estate, awarding PHP 198,000—PHP 180,000 in death compensation and PHP 18,000 for burial allowances.
Jurisdictional and Legislative Framework
The POEA asserted jurisdiction based on Section 4(a) of Executive Order No. 797, which grants it "original and exclusive jurisdiction over all cases, including money claims, involving employee-employer relations" pertaining to Filipino contract workers, including seamen. The Court recognized that the POEA's rulings are based on valid administrative regulations adopted under this executive order, specifically validating Memorandum Circular No. 2 that governs the award of benefits.
Judicial Precedent and Rationale
The Court referred to its earlier decision in Eastern Shipping Lines, Inc. v. POEA, which established that the POEA's jurisdiction includes claims for death and burial benefits for overseas workers. The ruling emphasized that the procedural objections raised by the petitioner, such as the non-resolution of a motion to dismiss prior to the merits decision, were not crucial in administrative proceedings where technical adherence to rules is not strictly enforced.
Factual Findings and Legal Obligations
The Court affirmed the POEA's factual findings that Urbiztondo was an overseas contract worker under Eastern Shipping Lines and entitled to benefits under the applicable regulations. The processing of the Shipping Articles by the POEA further supported Urbiztondo’s status as a qualified overseas
...continue readingCase Syllabus (G.R. No. 85061)
Case Overview
- The case involves a petition filed by Eastern Shipping Lines, Inc. challenging the decision of the Philippine Overseas Employment Administration (POEA) that awarded death and burial benefits to the private respondents, specifically to the estate of Francisco Urbiztondo.
- The main contention of the petitioner is that the POEA lacked jurisdiction over the claim, arguing that such claims should be directed to the Social Security System and charged to the State Insurance Fund.
Background and Facts
- Francisco Urbiztondo was hired for the duration of the voyage of the vessel "Eastern Galaxy," which commenced on November 9, 1985.
- He was disembarked from the vessel for medical treatment on December 13, 1985, and subsequently passed away.
- The records do not indicate that the voyage for which Urbiztondo was contracted had concluded at the time of his death.
- The POEA, upon review, determined that Urbiztondo was entitled to death compensation amounting to P180,000.00 and burial allowances of P18,000.00, totaling P198,000.00.
Jurisdictional Issues
- The petitioner argues that the POEA did not have jurisdiction over the employee's claim.
- Citing Executive Order No. 797, the Supreme Court reiterated that the POEA, as the successor to th