Case Summary (G.R. No. 219872)
Applicable Law
The relevant law applied in this case is the Philippine Overseas Employment Administration - Standard Employment Contract (POEA-SEC), specifically mentioning Section 20(B)(1) regarding compensation and benefits for work-related death of a seafarer.
Facts of the Case
In May 2011, Jaime was first employed by BMC, deployed on MV Go Public. He experienced health issues while on board, with symptoms like stomach pains, loss of appetite, and significant weight loss becoming apparent. After exhibiting further symptoms such as jaundice, he was hospitalized in China and later diagnosed with Hepatitis B and stage 4 Hepatocellular Carcinoma. His health deteriorated after repatriation, and he passed away due to cardio-respiratory arrest on January 18, 2012. Maximina filed a complaint for death benefits and other claims, asserting that Jaime's illness was work-related.
Initial Ruling
The Labor Arbiter dismissed Maximina's complaint on the grounds that Jaime's death was not work-related and did not occur during the contract term, only awarding burial benefits. Both the Labor Arbiter and subsequently, the National Labor Relations Commission (NLRC), affirmed that there was a lack of evidence linking Jaime's illness to his employment conditions.
Court of Appeals' Decision
Maximina appealed to the Court of Appeals (CA), which upheld the lower court's ruling, indicating that there was insufficient proof of causality between Jaime's work and his illness. The CA noted that while a pre-employment medical examination indicated Jaime was fit for duty, it did not guarantee he was free from disease.
Supreme Court Proceedings
Dissatisfied, Maximina petitioned the Supreme Court, reiterating her claims for death benefits on the premise that Jaime initially passed the medical examinations and that his working conditions might have aggravated his pre-existing health issues. The Court noted that while the company physician’s assessment indicated that liver cancer was non-work-related, the evidentiary burden of proof had not been sufficiently met by BMC to refute claims of work relation.
Court's Ruling
The Supreme Court ruled in favor of Maximina, establishing that Jaime's employment conditions likely aggravated his Hepatitis B, leading to liver cancer. The Court determined a causal connection between J
...continue readingCase Syllabus (G.R. No. 219872)
Background of the Case
- The case centers on the petition filed by Maximina T. Mabute and her four minor children against Bright Maritime Corporation (BMC) and Evalend Shipping Company regarding the denial of death benefits for her late husband, Jaime M. Mabute.
- The Court of Appeals’ decision dated December 19, 2014, denying the claim for death benefits and other remunerations under the Philippine Overseas Employment Administration - Standard Employment Contract (POEA-SEC) is being contested.
Facts of the Case
- Jaime Mabute was first employed by BMC in May 2011 as Chief Engineer on the MV Go Public, initially for a four-month contract, later extended for five months.
- In November 2011, Jaime began experiencing significant health issues, including stomach pain and weakness, leading to hospitalization in China in December.
- He was diagnosed with serious health conditions, including anemia and hepatitis, and was medically repatriated to the Philippines on January 1, 2012.
- Upon his return, Jaime was diagnosed with Hepatocellular Carcinoma Stage 4.
- He passed away on January 18, 2012, due to cardio-respiratory arrest and the cancer diagnosis.
Legal Proceedings
- Following Jaime's death, Maximina filed a complaint with the National Labor Relations Commission (NLRC) for death benefits, burial assistance, and damages.
- BMC denied the claims, asserting that Jaime's illness was not