The Supreme Court held that when a seafarer’s death occurs during the term of employment, the employer is liable for death compensation benefits unless it can prove that the death was a result of the seafarer’s deliberate or willful act. This ruling clarifies the evidentiary burden on employers seeking to avoid liability in death benefit claims, emphasizing that the burden of proof rests on the employer to demonstrate that the seafarer’s death was self-inflicted to be exempt from paying death compensation benefits. The Court underscored that the findings of a foreign medical examiner, who personally examined the site, holds substantial weight over findings that did not conduct an autopsy or examine the site of the incident.

When a Seafarer’s Tragic End Becomes a Legal Battle: Determining Liability in a Claim for Death Benefits

This case revolves around the death of Hernani Pedrajas, an Engine Boy on board the M/V Crown Jade. While the vessel was in Italy, Hernani was found hanging, leading to conflicting investigations about whether his death was a suicide or homicide. The central legal question is whether the employer, Wallem Maritime Services, Inc., is obligated to pay death benefits to Hernani’s beneficiaries under the POEA-SEC and AMOSUP-CBA, or if the death was self-inflicted and thus exempt from coverage.

Section 20 (D) of the POEA-SEC stipulates the conditions under which compensation and benefits are not payable. It states:

No compensation and benefits shall be payable in respect of any injury, incapacity, disability or death of a seafarer resulting from his willful or criminal act or intentional breach of his duties x x x.

The general rule is that the death of a seaman during the term of his employment makes the employer liable to the former’s heirs for death compensation benefits. However, this liability is not absolute. The employer can be exempt if it proves that the seaman’s death was caused by an injury directly attributable to his deliberate or willful act. Therefore, the entitlement to death benefits hinges on whether the employer’s evidence sufficiently proves that Hernani committed suicide; the burden of proof rests on the employer.

In this case, the Italian Medical Examiner’s report played a crucial role. The examiner concluded:

Therefore no elements at all have emerged such as would lead us to believe that third parties may have intervened in causing the death, and the way in which Mr. Pedrajas died, as described, conforms to suicide.

The Italian Medical Examiner, after a thorough investigation, concluded that Hernani’s death was a suicide. The Court of Appeals (CA), however, gave less weight to this report, citing conflicting findings from the PNP Crime Laboratory and the NBI. The PNP Crime Laboratory stated:

Based on the following information and physical findings, I cannot totally rule-out homicide.

The NBI’s Medico-Legal Officer also concluded that “HOMICIDE cannot be totally ruled out.” The Supreme Court found it more logical to rely on the Italian Medical Examiner’s findings, noting the depth and immediacy of the examination. In Maritime Factors, Inc. v. Hindang, the Supreme Court had previously given credence to a medical report made by a Saudi Arabian doctor who immediately conducted an autopsy, emphasizing the value of a first-hand examination.

The Court noted that the Italian Medical Examiner’s findings were based on a personal and careful examination of the incident site immediately after the discovery of the body. The examiner had the advantage of investigating the crime scene, examining the rope used, and assessing the body’s position. The Labor Arbiter (LA) highlighted this, stating that the Italian Medical Examiner’s report proved that Hernani hanged himself, disqualifying his heirs from death benefits under the POEA Contract and the CBA.

The Supreme Court also addressed the suicide notes left by Hernani. While the CA did not give weight to these notes due to the lack of original copies, the Supreme Court emphasized that proceedings before the NLRC are not strictly bound by technical rules of evidence. The Labor Arbiter compared the suicide notes to other documents and concluded they were written by Hernani. Additionally, the petitioners explained that the original notes were in the possession of Italian authorities as evidence in their investigation.

The credibility and authenticity of Hernani’s suicide notes were deemed beyond doubt, especially since information in the notes led to the arrest of Deck Boy Harder, who confessed to drug operations. This confession corroborated the notes’ content, supporting their genuineness and truthfulness. Since the employer was able to sufficiently prove Hernani committed suicide, his death is not compensable.

The ruling reinforces the principle that when a seaman’s death results from a deliberate act on his own life, and this act is directly attributable to him, the death is not compensable.

FAQs

What was the key issue in this case?	The key issue was whether the death of the seafarer, Hernani Pedrajas, was a suicide, which would exempt the employer from paying death benefits to his beneficiaries.
What is Section 20 (D) of the POEA-SEC?	Section 20 (D) of the POEA-SEC states that no compensation and benefits are payable if the seafarer’s death resulted from his willful or criminal act or intentional breach of duties. This provision outlines the conditions under which an employer is not liable for death benefits.
Who has the burden of proof in determining the cause of death?	The burden of proof rests on the employer to demonstrate that the seafarer’s death was self-inflicted to be exempt from paying death compensation benefits. This means the employer must provide sufficient evidence to prove the seafarer committed suicide.
Why did the Supreme Court give more weight to the Italian Medical Examiner’s report?	The Supreme Court favored the Italian Medical Examiner’s report because the examiner personally and carefully examined the site of the incident immediately after the body was discovered. The examiner’s findings were based on direct observation and investigation of the scene.
What role did the suicide notes play in the Supreme Court’s decision?	The suicide notes, though photocopies, were considered by the Supreme Court because proceedings before the NLRC are not strictly bound by technical rules of evidence. The content of the notes, which led to the arrest of a crew member involved in drug operations, supported their credibility and authenticity.
Can the employer be exempted from paying death benefits?	Yes, the employer can be exempted from paying death benefits if it is proven that the seafarer’s death resulted from a deliberate or willful act on his own life. In this case, the employer successfully proved that the seafarer committed suicide.
What was the significance of the Maritime Factors, Inc. v. Hindang case?	The Maritime Factors, Inc. v. Hindang case was cited to support the principle of giving credence to medical reports based on first-hand examinations conducted immediately after death. This case emphasized the importance of direct observation in determining the cause of death.
What happens if the cause of death is uncertain?	If the cause of death remains uncertain, the employer may still be liable for death benefits, as the burden of proof lies on the employer to demonstrate that the death was self-inflicted. In this case, the initial uncertainty was resolved by the thoroughness of the Italian Medical Examiner’s report and corroborating evidence from the suicide notes.

This case underscores the importance of thorough investigations and credible evidence in determining liability in seafarer death benefit claims. It clarifies the evidentiary burden on employers and highlights the significance of first-hand medical examinations in establishing the cause of death.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: WALLEM MARITIME SERVICES, INC. VS. DONNABELLE PEDRAJAS, G.R. No. 192993, August 11, 2014