CASE DIGEST: Marlow Navigation v. Heirs of Ganal

 


MARLOW NAVIGATION PHILIPPINES, INC./MARLOW NAVIGATION CO., LTD. And/or MS. EILEEN MORALES, petitioners, vs. HEIRS OF RICARDO S. GANAL, GEMMA B. BORAGAY, for her behalf and in behalf of her minor children named: RIGEM GANAL & IVAN CHARLES GANAL; and CHARLES F. GANAL, represented by SPOUSES PROCOPIO & VICTORIA GANAL, respondents
G.R. No. 220168                |              June 7, 2017

FACTS:

Ricardo Ganal worked as an oiler aboard MV Stadt Hamburg starting Sept. 20, 2011. On the evening of April 15, 2012, the crewmen of MV Stadt Hamburg organized a party while they were still anchored at Chittagong, Bangladesh. Ganal joined the said party after finishing his shift at 12 MN. At around 3 AM, the ship captain that Ganal was already drunk so he directed him to return to his cabin and take a rest. Ganal ignored the ship captain’s order. Thus, the captain summoned 3 men to escort Ganal to his cabin. The crew members attempted to accompany him back to his cabin but he refused. They then tried to restrain him but he resisted and, when he found the chance to escape, he ran towards the ship’s railings and, without hesitation, jumped overboard and straight into the sea. Ganal was later found dead and floating in the water.

Subsequently, Ganal’s wife, Gemma Boragay, for herself and in behalf of their minor children, filed a claim for death benefits with petitioners, but the latter denied the claim. Thus, on October 29, 2012, Boragay, filed with the NLRC a complaint for recovery of death and other benefits, unpaid salaries for the remaining period of Ganal’s contract, as well as moral and exemplary damages.

The LA dismissed the complaint for lack of merit. It held that respondents’ allegations are self-serving and hearsay; they failed to present evidence to substantiate their allegations; on the other hand, petitioners were able to present affidavits of Ganal’s fellow crew members who have direct and actual knowledge of what occurred on board the MV Stadt Hamburg and who attested to the fact that Ganal willfully jumped overboard.

The NLRC affirmed the LA’s Decision. It ruled that petitioners have duly proven that Ganal’s death is not compensable as it was the result of the deliberate and willful act of Ganal and, thus, is directly attributable to him.

The CA, however, reversed the LA and the NLRC’s Decision. It held that Ganal jumped into the sea while he was overcome by alcohol and completely intoxicated and deprived of his consciousness and mental faculties to comprehend the consequence of his own actions and keep in mind his own personal safety.

ISSUE:

Whether or not Ganal’s death is willful and is therefore not compensable

RULING:

In the present case, it may be conceded that the death of Ganal took place in the course of his employment, in that it happened at the time and at the place where he was working. However, the accident which produced this tragic result did not arise out of such employment. The occasion where Ganal took alcoholic beverages was a grill party organized by the ship officers of MV Stadt Hamburg. It was a social event and Ganal attended not because he was performing his duty as a seaman, but was doing an act for his own personal benefit. Even if the Court were to adopt a liberal view and consider the grill party as incidental to Ganal’s work as a seaman, his death during such occasion may not be considered as having arisen out of his employment as it was the direct consequence of his decision to jump into the water without coercion nor compulsion from any of the ship officers or crew members. The hazardous nature of this act was not due specially to the nature of his employment. It was a risk to which any person on board the MV Stadt Hamburg, such as a passenger thereof or an ordinary visitor, would have been exposed had he, likewise, jumped into the sea, as Ganal had.

The term “willful” means “voluntary and intentional,” but not necessarily malicious. In the instant case, Ganal’s act of intentionally jumping overboard, while in a state of intoxication, could be considered as a deliberate and willful act on his own life which is directly attributable to him.

Moreover, contrary to respondents’ contention, petitioners took the necessary precautions when: (1) the ship captain advised Ganal to proceed to his cabin and take a rest; (2) Ganal was assisted by no less than three crew members who tried to persuade him to return to his cabin; (3) when he refused, the crew members tried to restrain him but he escaped and immediately ran away from them and, without warning, jumped into the sea.

The law does not intend for an employer to be the insurer of all accidental injuries befalling an employee in the course of the latter’s employment, but only for those which arise from or grow out of the risks necessarily associated with the workman’s nature of work or incidental to his employment. Ganal’s act of jumping overboard was not, in any way, connected with the performance of his duties as ship oiler. Neither could petitioners have reasonably anticipated such act on the part of Ganal. Thus, having proven their defense, the burden now rests on the shoulders of respondents to overcome petitioners’ defense.

Respondents failed to present evidence to overcome the defense of petitioner and show that, prior to and at the time that he jumped overboard, Ganal was deprived of the use of his reason or that his will has been so impaired, by reason of his intoxication, as to characterize his actions as unintentional or involuntary. Ganal may have become unruly by reason of his inebriation but such recalcitrant behaviour does not necessarily prove that his subsequent act of jumping overboard was not willful on his part. The fact alone that he refused to be escorted to his cabin, that he resisted efforts by other crew members to restrain him and that he jumped overboard without hesitation or warning does not prove that he was not in full possession of his faculties as to characterize his acts as involuntary or unintentional.

If it could be shown that a person drank intoxicating liquor, it is incumbent upon the person invoking drunkenness as a defense to show that said person was extremely drunk. It must be shown that the intoxication was the proximate cause of death or injury and the burden lies on him who raises drunkenness as a defense.

Indeed, Ganal may have had no intention to end his own life. For all we know he was just being playful. Nonetheless, he acted with notorious negligence. Notorious negligence has been defined as something more than mere or simple negligence or contributory negligence; it signifies a deliberate act of the employee to disregard his own personal safety. In any case, regardless of Ganal’s motives, petitioners were able to prove that his act of jumping wilful on his part.


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