Case Summary (G.R. No. 76633)
Petitioner
Eastern Shipping Lines, Inc., owner of the M/V Eastern Polaris, challenges the jurisdiction and award of the Philippine Overseas Employment Administration (POEA).
Respondents
Philippine Overseas Employment Administration; Minister of Labor and Employment; Hearing Officer Abdul Basar; and Kathleen D. Saco.
Key Dates
• Executive Order No. 797 creating the POEA: May 1, 1982
• POEA Memorandum Circular No. 2 (standard contract): February 1, 1984
• Fatal accident: March 15, 1985
• Supreme Court decision: October 18, 1988
Applicable Law
• 1973 Philippine Constitution
• Executive Order No. 797 (Sec. 4[a] vests POEA with original and exclusive jurisdiction over money claims involving Filipino contract workers, including seamen)
• POEA Rules and Regulations on Overseas Employment (1985)
• POEA Memorandum Circular No. 2, Series of 1984 (model seamen’s employment contract)
• Presidential Decree No. 1694 (Welfare Fund for Overseas Workers)
• Labor Code; Social Security Law; Employees’ Compensation provisions
Facts
Under a valid employment contract, Saco served aboard the M/V Eastern Polaris. Upon his death in Tokyo, his widow lodged a complaint with the POEA, which awarded ₱180,000 for death benefits and ₱12,000 for burial expenses (total ₱192,000). Eastern Shipping Lines contended that Saco was a domestic, not overseas, employee and that the proper forum was the Social Security System and Employees’ Compensation Commission.
Jurisdiction Issue
Eastern Shipping Lines argued that POEA lacked jurisdiction because Saco was not an “overseas worker.” The POEA invoked Executive Order No. 797, Section 4(a), granting it exclusive original jurisdiction over money claims arising from contracts involving Filipino contract workers, including seamen, working abroad or on vessels in international waters.
Employment Classification
The 1985 POEA Rules define “overseas employment” as service outside the Philippines, including on vessels plying international waters under valid contracts, and “contract worker” as anyone working overseas under contract, expressly including seamen. The Court upheld the POEA’s factual finding that Saco qualified as an overseas employee at the time of his death.
Regulatory Compliance
Eastern Shipping Lines had submitted its shipping articles to the POEA for approval and paid contributions to the Welfare Fund for Overseas Workers—acts that tacitly recognized Saco’s status as an overseas contract worker. The Welfare Fund receipt even described him as such.
Validity of Memorandum Circular No. 2
Memorandum Circular No. 2 prescribed a standard employment contract for Filipino seamen engaged in overseas service. Executive Order No. 797, Section 4(a), expressly authorized the POEA Board to promulgate rules and regulations governing its adjudicatory functions. The Court found that such rulemaking is a valid exercise of delegated legislative authority, subject to the “completeness” and “sufficient standard” tests under the non-delegation doctrine, with the guiding principle being the protection of overseas Filipino workers and assurance of fair and equitable employment practices.
Non-Delegation and Administrative Rulemaking
The Court recognized that modern governance necessitates administrative bodies’ power to issue implementing regulations under a clear legislative framework. Memorandum Circular No. 2 fills in policy details left by Executive Order No. 797 without usurping legislative discretion, as it is guided by the mandate to safeguard workers’ rights.
Benefits and Reservat
...continue readingCase Syllabus (G.R. No. 76633)
Procedural History
- The private respondent’s claim for P192,000.00 (death benefits and burial expenses) was awarded by the POEA.
- Eastern Shipping Lines, Inc. (petitioner) challenged the award before the Supreme Court on jurisdictional grounds.
- Solicitor General moved to dismiss for non-exhaustion of administrative remedies; Supreme Court found exception due to pure questions of law and private respondent’s acquiescence.
- Temporary restraining order of December 10, 1986, was lifted; petition was dismissed with costs.
Facts
- Vitaliano Saco served as Chief Officer of M/V Eastern Polaris.
- Saco died in an accident in Tokyo, Japan, on March 15, 1985.
- Widow Kathleen D. Saco sued under Executive Order No. 797 and POEA Memorandum Circular No. 2.
- Eastern Shipping Lines argued the claim belonged before the Social Security System and State Insurance Fund.
Issue
- Whether the POEA had original and exclusive jurisdiction to hear and decide the widow’s claim for death and burial benefits.
Applicable Statutes and Regulations
- Executive Order No. 797 (May 1, 1982): creates POEA; grants original and exclusive jurisdiction over Filipino contract workers (including seamen).
- 1985 Rules and Regulations on Overseas Employment (POEA Rule I, Sec. 1(d); Rule II, Secs. 1(x), 1(g)).
- POEA Memorandum Circular No. 2 (effective February 1, 1984): prescribes standard seamen contract; provides death and burial benefits.
- P.D. No. 1694: Welfare Fund for Overseas Workers.
Jurisdictional Determination
- POEA’s jurisdiction extends to “employee-employer relations” involving Filipino contract workers overseas, including claims for death and disability benefits.
- Saco was employed under a valid overseas contract while his vessel was in foreign waters.
- Petitioner’s own conduct—submission of shipping