CASE DIGEST: Mabuhay Shipping Services v. NLRC

 


MABUHAY SHIPPING SERVICES, INC. AND SKIPPERS MARITIME CO., LTD., petitioners, vs. HON. NATIONAL LABOR RELATIONS COMMISSION (FIRST DIVISION) AND CECILIA SENTINA, respondents
G.R. No. 94167                  |              Jan. 21, 1991

FACTS:

Romulo Sentina was hired as a 4th Engineer on board M/V Harmony I starting from July 13, 1987.

On January 16, 1988 at about 3 p.m., while the vessel was docked alongside Drapetona Pier, Piraeus, Greece, Sentina arrived aboard the ship from shore leave visibly drunk. He became violent and started challenging his other shipmates to fight. He smashed and threw a cup towards the head of an oiler, Emmanuel Ero, who was then eating. This infuriated Ero which led to a fight between them. After the shipmates broke the fight, Sentina was taken to the hospital where he passed away.

Private respondents filed a complaint for payment of death benefits, burial expenses, unpaid salaries and overtime pay with the POEA. The POEA ruled in favor of private respondent and ordered Mabuhay Shipping Services, Inc. and Skippers Maritime Co., Ltd. to pay complainant Cecilia S. Sentina death benefits and burial compensation, as well as, unpaid shipboard pay, fixed overtime pay, and attorney’s fees. It held that payment of death compensation benefits only requires that the seaman should die during the term of the contract and no other. It further held that the saving provision relied upon by petitioners refers only to suicide where the seaman deliberately and intentionally took his own life.

A motion for reconsideration and/or appeal was filed by petitioners with the First Division of the National Labor Relations Commission, which dismissed the appeal and affirmed the POEA’s Decision.

ISSUE:

Whether or not respondent is entitled to death compensation benefit

RULING:

The mere death of the seaman during the term of his employment does not automatically give rise to compensation. The circumstances which led to the death as well as the provisions of the contract, and the right and obligation of the employer and seaman must be taken into consideration, in consonance with the due process and equal protection clauses of the Constitution. There are limitations to the liability to pay death benefits.

When the death of the seaman resulted from a deliberate or wilful act on his own life, and it is directly attributable to the seaman, such death is not compensable.

As in this case the seaman, in a state of intoxication, ran amuck, or committed an unlawful aggression against another, inflicting injury on the latter, so that in his own defense the latter fought back and in the process killed the seaman, the circumstances of the death of the seaman could be categorized as a deliberate and wilful act on his own life directly attributable to him. The death of Sentina is attributable to his unlawful aggression and thus is not compensable.


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