Case Summary (G.R. No. 77828)
Facts of the Case
Manuel Zaragoza had been employed with Eastern Shipping Lines since 1973. His death in Kakogawa, Japan was attributed to myocardial infarction. Following his death, Ma. Lourdes filed a complaint with the POEA on December 17, 1985, seeking death benefits amounting to PHP 100,000, along with moral damages of PHP 50,000 and attorney's fees. Eastern Shipping Lines responded that it had already provided a cash benefit of PHP 12,000 for death and PHP 5,000 for funeral expenses, asserting that Ma. Lourdes’ claim was baseless.
Jurisdictional Issues
Eastern Shipping challenged the jurisdiction of the POEA, arguing that it was not engaged as an overseas employer and that the claims should have been directed to the Social Security System. However, the court ruled that the POEA had original and exclusive jurisdiction over cases arising from employer-employee relations involving Filipino workers overseas, which includes seamen. This is supported by Executive Order No. 797 and related regulations, affirming that the POEA governs claims related to death and disability benefits for seafarers.
Employment Status and Relevant Law
The court established that at the time of his death, Manuel Zaragoza was indeed an employee of Eastern since he was under a valid employment contract as a seaman on a vessel operating outside Philippine waters. The fact that Eastern submitted its shipping articles to POEA demonstrated its acknowledgment of the regulatory authority over overseas employment.
Death Benefits Assessment
The POEA relied on Memorandum Circular No. 71, which outlined the compensation due for the death of a seaman. The circular mandates that employers pay a fixed amount to the beneficiaries of seamen who die while under contract. Eastern Shipping contested the applicability of this circular, arguing that it contradicted principles of non-delegation of legislative powers, but the court affirmed the validity of the circular, recognizing the authority of the NSB (National Seamen Board) and its successor, POEA.
Registration and Coverage Arguments
The petitioner attempted to argue that the M/V Eastern Meteor's dual registration—both in Panama and the Philippines—exempted it from the purview of Memorandum Circular No. 71. However, the court clarified that the underlying intent of the regulation was to ensure t
...continue readingCase Syllabus (G.R. No. 77828)
Introduction
- This case concerns a Petition for Certiorari and Prohibition filed by Eastern Shipping Lines, Inc. against the Philippine Overseas Employment Administration (POEA) and other respondents.
- The petition aims to annul the POEA's decision dated 19 March 1987 regarding the entitlement of Ma. Lourdes A. Zaragoza to death benefits following the death of her husband, Manuel Zaragoza.
Facts of the Case
- Manuel Zaragoza was employed by Eastern Shipping Lines, Inc. for several years, serving as Chief Engineer on various vessels since 1973.
- He died on 18 September 1983 while serving on the M/V Eastern Meteor, a vessel chartered by Eastern and registered with Freesia Shipping Company S.A.
- The cause of death, as per a death certificate issued in Japan, was "myocardial infarction."
- On 17 December 1985, Ma. Lourdes A. Zaragoza filed a formal complaint with the POEA for gratuity benefits, alleging entitlement to P100,000.00 as per NSB Memorandum Circular No. 71, along with moral damages and attorney's fees.
- Eastern Shipping Lines contested the claim, stating that they had already provided a cash benefit of P12,000.00 and P5,000.00 for funeral expenses, and that they were not liable for any additional benefits under the Memorandum Circular.
Procedural History
- The POEA issued a decision requiring Eastern to pay