Case Summary (G.R. No. 172378)
Background of Employment and Incident
Edville was hired on October 9, 2015, and boarded the vessel on October 14, 2015. During his employment, he began exhibiting health problems on October 19, which escalated, leading to his collapse and subsequent death on October 20, 2015. The immediate cause of death was established to be pneumonia, evolving from symptoms that appeared shortly after Edville commenced his duties on the ship.
Proceedings Before the Labor Arbiter
Two separate complaints for death benefits were filed; one by Edville's legitimate family and the other by his illegitimate child. The Labor Arbiter ruled in favor of the legitimate child, granting $10,000 as death benefits, $7,000 for being a minor, and $1,700 as attorney’s fees. The Labor Arbiter noted Edville's deteriorating condition resulted from his working conditions and that the employer's failure to provide timely medical attention contributed to the death.
NLRC Ruling and Reversal of Labor Arbiter's Decision
The National Labor Relations Commission (NLRC) later reversed the Labor Arbiter’s decision regarding the legitimate child, holding that the evidence failed to connect Edville's pneumonia directly to his employment. Conversely, the NLRC upheld the illegitimate child’s claim under similar facts, citing sufficient evidence establishing work-relatedness and compensability of Edville's condition, concluding that he contracted pneumonia while employed.
Court of Appeals' Dismissals
The Court of Appeals dismissed both parties' petitions, affirming the NLRC findings in the case involving the illegitimate child's claim, while rejecting the claim of the legitimate family based on the assertion that pneumonia was not recognized as an occupational disease warranting compensation without substantial proof of work-related causation.
Supreme Court Review and Legal Principles
Upon reviewing the cases, the Supreme Court emphasized the interpretation of the 2010 Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC). Specifically, illnesses not listed under its provisions are disputably presumed work-related, shifting the burden of proof to the employer to demonstrate that the illness was not work-related.
Ruling and Interpretation of the Law
The Court granted the petition of Ethyl and Travez, establishing that they are entitled to statutory death benefits as Edville's death was work-related and occurred during the term of his contract. The obligations of Thenamaris and associated parties encompass $50,000 in death benefits, additional amounts for minor children, burial e
...continue readingCase Syllabus (G.R. No. 172378)
Overview of the Case
- This case involves two consolidated Petitions for Review on Certiorari under Rule 45 of the Rules of Court.
- G.R. No. 241844 involves petitioners Ethyl Huiso Ebal and her minor child, Travez, seeking to reverse a Court of Appeals decision that dismissed their petition for death benefits and damages stemming from the death of Edville Cliano Beltran.
- G.R. No. 257584 involves the respondents Thenamaris Philippines, Inc., Narcissus Enterprises S.A., and certain captains, contesting a decision that awarded death benefits to the heirs of Edville.
Background Facts
- Edville was employed by Thenamaris as a Third Engineer aboard M/T Seacross for a seven-month contract starting October 14, 2015.
- He exhibited health issues shortly after boarding, including trembling and respiratory difficulties, and was ultimately declared dead on October 20, 2015, due to pneumonia.
- Following Edville's death, his heirs filed separate complaints for death benefits and damages against his employers.
Rulings of the Labor Arbiter
- The Labor Arbiter in G.R. No. 241844 found Edville's employers jointly and severally liable for death benefits, concluding that Edville's work conditions contributed to the onset of his pneumonia.
- Conversely, in G.R. No. 257584, the Labor Arbiter ruled against Ju-Ann and Jhun, Edville's other heirs, citing insufficient evidence for their claims regarding the work-relatedness of Edville's death.