Case Summary (G.R. No. 167678)
Factual Antecedents
Federico U. Navarra, Jr. was employed by Southeastern Shipping to work on the vessel "George McLeod" under ten successive employment contracts from October 5, 1995, to March 30, 1998. His final contract was approved by the Philippine Overseas Employment Administration (POEA) on January 21, 1998, allowing for a duration of 56 days, extendable for an additional 56 days. While onboard, he experienced health issues starting March 6, 1998, culminating in a diagnosis of Hodgkin's Lymphoma on June 4, 1998. Federico filed a complaint for disability benefits on September 6, 1999, but passed away on April 29, 2000. His widow Evelyn subsequently pursued death benefits.
Ruling of the Labor Arbiter
The Labor Arbiter dismissed Evelyn's complaint on May 10, 2000, asserting that Hodgkin's Lymphoma was not classified as an occupational disease and that the claim lacked merit.
Ruling of the National Labor Relations Commission (NLRC)
The NLRC reversed the Labor Arbiter's decision on May 7, 2003, ruling that petitioners were liable to pay Evelyn death compensation of $50,000, allowances for minor children, and burial expenses, totaling $72,000 plus attorney's fees.
Ruling of the Court of Appeals
The Court of Appeals upheld the NLRC's decision, finding that the claim for death benefits had not prescribed and that the cause of Federico’s death, which was related to the illness incurred during employment, necessitated compensation despite the expiration of his contract.
Issues Raised by Petitioners
Petitioners contended that the appeals court erred in:
- Ruling that the prescription period for the complaint had not expired.
- Classifying Hodgkin's Disease as a compensable illness under the employment contract.
- Concluding that they were liable for benefits since Federico's death occurred after the termination of his contract.
Petitioners' Arguments
Petitioners maintained that the Court of Appeals' determinations lacked evidentiary support, arguing that Federico was treated for an acute respiratory tract infection rather than Hodgkin's Disease while onboard. They also emphasized that the claim had prescribed due to its filing 17 months post-contract and that comprehensive evidence substantiated that the cause of death was unconnected to his employment.
Respondents' Arguments
In response, respondents argued that the claims were timely as the prescriptive period extends three years from when the cause of action arises. They asserted that Hodgkin's Disease stemmed from conditions experienced while onboard, thus making it compensable.
Our Ruling
The petition was partially granted, affirming the finding that the death benefits claim had not yet prescribed. Nonetheless, the court ruled that petitioners were not liable for deat
...continue readingCase Syllabus (G.R. No. 167678)
Background of the Case
- The case revolves around a petition for review concerning money claims arising from employer-employee relations, specifically between the petitioners, Southeastern Shipping and Southeastern Shipping Group, Ltd., and the respondent, Federico U. Navarra, Jr.
- The primary issue involves the entitlement to death benefits following the death of Federico, who was diagnosed with Hodgkin's Lymphoma after his employment contract had expired.
- The case was decided by the Supreme Court on June 22, 2010, following prior decisions by the National Labor Relations Commission (NLRC) and the Court of Appeals (CA).
Factual Antecedents
- Federico was hired by Southeastern Shipping to work aboard the vessel "George McLeod" and signed 10 successive employment contracts from October 5, 1995, to March 30, 1998.
- His last employment contract was approved by the Philippine Overseas Employment Administration (POEA) on January 21, 1998, and he worked as a motorman.
- Federico fell ill on March 6, 1998, while at sea, exhibiting symptoms such as a sore throat and fever, and was treated with medication.
- Upon returning to the Philippines on March 30, 1998, a biopsy on April 21, 1998, confirmed no malignancy, but by June 4, 1998, he was diagnosed with Hodgkin's Lymphoma.
- Federico filed a complaint for disability benefits with the NLRC on September 6, 1999, but died on April 29, 2000. His widow, Evelyn, substituted him, converting the claim to death benefits.
Ruling of the Labor Arbiter
- On May 10, 2000, the Labor Arbiter dismissed the complaint, ruling that Hodgkin's Lymphoma was not a compensable illness under the relevant laws.
- The dismissal was based on the assertion that the exact cause of the illness was unknown.
Ruling of the NLRC
- On May 7, 2003, the NLRC reversed the Labor Arbiter's decision, ordering the petitioners to pay Evelyn death compensation, allowances