Case Summary (G.R. No. 151993)
Factual Background
Danilo R. Hindang was found dead on July 27, 1994, on board the vessel while docked in Saudi Arabia. Investigating authorities, including the Saudi police and Dr. Ossman Abdel Hameed, the Medical Examiner, concluded that he died by suicide through hanging. However, following the repatriation of Danilo's remains to the Philippines, a second autopsy conducted by Dr. Maximo L. Reyes of the National Bureau of Investigation (NBI) determined the cause of death as "Asphyxia by Strangulation, Ligature," suggesting that his death was caused by foul play.
Proceedings Before the Labor Arbiter
On August 24, 1994, Bienvenido R. Hindang filed a claim for death compensation benefits. The Labor Arbiter examined the conflicting medical reports and determined that Danilo did not commit suicide, thereby ruling in favor of granting death benefits as per the POEA Standard Contract. The Labor Arbiter concluded that the evidentiary weight lay with the NBI's report over the unverified photocopied documentation presented by the petitioner.
Appeal to the National Labor Relations Commission (NLRC)
Following the Labor Arbiter's decision, the petitioner appealed to the NLRC. The NLRC upheld the Labor Arbiter’s ruling, emphasizing the need for the employer to provide clear evidence that Danilo’s death was not compensable due to suicide. The NLRC reiterated that the burden of proof rested with the petitioner but found that they did not adequately discharge this burden.
Review by the Court of Appeals
The petitioner's subsequent appeal to the Court of Appeals was likewise denied. The Court reaffirmed the evidentiary standards set forth by the NBI report and the incompleteness and unreliability of the petitioner’s evidence. The CA stated that the employer’s evidence did not alter the liability imposed by the POEA regulations regarding death benefits.
Supreme Court's Ruling
Upon its review, the Supreme Court determined that although the lower tribunals had dismissed the medical report from Dr. Hameed for being a mere photocopy, the report had actually been referenced in parts acceptable to the respondent when advantageous. This led to findings that the petitioner was indeed siding with favorable excerpts while simultaneously arguing against the report's reliability as a whole. The Supreme Court indicated that the procedural leeway extended to admini
...continue readingCase Syllabus (G.R. No. 151993)
Background of the Case
- The case involves a petition for review on certiorari filed by Maritime Factors Inc. against Bienvenido R. Hindang, the brother of deceased seaman Danilo R. Hindang.
- The petition challenges the Decision dated November 28, 2001, and the Resolution dated January 29, 2002, from the Court of Appeals (CA) in CA-G.R. SP No. 57478.
Employment Details
- Danilo R. Hindang was engaged by Maritime Factors Inc., a domestic manning agency, to work as GP/Deckhand on the Panamanian-registered vessel M/T "Reya."
- His employment contract was for 12 months, with a basic monthly salary of US$230.00.
Circumstances of Death
- On July 27, 1994, while in Saudi Arabia, crew members found Danilo dead in his cabin, hanging by a strap in a kneeling position.
- The Saudi police were notified, and an autopsy was conducted by Dr. Ossman Abdel Hameed, who concluded that Danilo's death was a suicide.
Autopsy Findings
- Danilo's remains were repatriated to the Philippines, where an autopsy by Dr. Maximo L. Reyes of the NBI found the cause of death to be asphyxia by strangulation, suggesting homicide rather than suicide.
- Dr.