Title
Supreme Court
Spouses Dalen vs. Mitsui O.S.K. Lines
Case
G.R. No. 194403
Decision Date
Jul 24, 2019
Heirs of deceased seafarers sued for damages after MV Sea Prospect sank, but settlement agreements waived claims; SC upheld validity, barring further action.

Case Summary (G.R. No. 194403)

Facts of the Case

The petitioners filed a complaint for damages and attorney's fees against the respondents following an incident where the MV Sea Prospect sank, resulting in the deaths of ten crew members. The vessel, which had been transporting wet nickel ore, developed a list due to inclement weather, eventually sinking and taking the lives of several crew members. The respondents claimed that the petitioners received compensation for the crew members' deaths in accordance with both the individual employment contracts and a collective bargaining agreement.

Settlement Agreements

Respondents asserted that the petitioners had signed settlement agreements, which included clauses releasing the respondents from all liabilities related to the deaths arising from the sinking. These agreements were allegedly understood fully by the petitioners, who were accompanied by legal counsel during the signing. As per the agreements, the petitioners committed not to pursue further claims against the respondents in any jurisdiction.

Jurisdiction Issues

The Labor Arbiter initially dismissed the case for lack of jurisdiction, as the claims for damages were based on tort rather than employer-employee relations. It was determined that the action was one in personam, necessitating proper service of summons on the foreign respondents. Moreover, the claim was found to have already prescribed, as the three-year period for filing the claim under the Labor Code had lapsed.

Legal Analysis of Settlement Validity

The Supreme Court elucidated that the signed waivers and settlement agreements were binding and valid, emphasizing that not all such agreements are rendered ineffective against public policy. The court underscored the importance of whether the waiver was voluntarily and knowingly executed. In this instance, the absence of evidence showing that the petitioners were misled or coerced pointed to the agreements holding legal weight.

Conclusion on Prescriptive Claims

Ultimately, the Supreme Court ruled affirmatively on the validity of the settlement agreements signed by the petitioners, determining that they constituted an absolute bar

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