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TSM Shipping and MST Marine Services vs. Shirley De Chavez

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TSM Shipping and MST Marine Services vs. Shirley De Chavez

Case Title and Citation

TSM SHIPPING (PHILS.), INC., and MST MARINE SERVICES PHILS., INC., petitioners, vs. Shirley G. De Chavez, respondent.
G.R. No. 198225, September 27, 2017
Supreme Court - First Division
Ponente: Del Castillo, J.

Facts

  • On August 23, 2005, petitioners hired Ryan Pableo De Chavez as chief cook on board the oil tanker Haruna Express for a nine-month period.
  • On February 26, 2006, Ryan was found dead inside his cabin bathroom, hanging by the shower cord and covered with blood.
  • Shirley De Chavez (wife) filed a complaint for death benefits under the POEA Standard Employment Contract.
  • Documentary evidence submitted by petitioners included:
    1. A Medical Certificate of Death issued by Dr. Sung Yeoul Hung of Ulsan City Hospital stating the direct cause of death as “Intentional Self-Harm by [Hanging], Strangulation and Suffocation” and noting blood loss.
    2. An INTECO (International Inspection and Testing Corporation) Investigation Report describing the circumstances: shower hose around the neck, a 5 cm cut on the left wrist, a pair of scissors in the bathroom, autopsy performed at Ulsan City Hospital, and concluding the cause of death as suicide (excessive bleeding from wrist cut and other findings).
    3. Written statements of ship personnel (including Messman Melendres) reporting no signs of struggle and describing discovery of the body.
    4. A personnel manager’s statement indicating possible motive related to family financial pressure.
  • The Labor Arbiter dismissed the complaint (July 18, 2009), finding the evidence showed suicide.
  • The NLRC initially dismissed for procedural deficiency, reinstated the appeal, and on December 16, 2009 affirmed the Labor Arbiter’s finding that Ryan committed suicide and denied death benefits.
  • The Court of Appeals granted Shirley’s petition for certiorari and on January 31, 2011 annulled the NLRC decision and remanded for computation of death benefits, finding insufficient evidence of suicide and questioning the INTECO report’s authority and discrepancies between documents.
  • Petitioners filed a petition for review on certiorari with the Supreme Court challenging the CA ruling.

Issues

  1. Is the Court of Appeals correct in ruling that the National Labor Relations Commission committed grave abuse of discretion in denying Shirley’s claim for death benefits?

Ruling

  1. No - The Court of Appeals erred; the Supreme Court held that the NLRC did not commit grave abuse of discretion and that substantial evidence supports the finding that the seafarer committed suicide, thus death benefits are not payable under the POEA-SEC.

Reasoning / Ratio Decidendi

  • Standard of review: Under Rule 45, the Supreme Court reviews whether the CA correctly determined the presence or absence of grave abuse of discretion by the NLRC; when CA and NLRC findings conflict, the Court may examine the records to decide if the CA had sufficient basis to reverse. (Cited: Unicol Management Services, Inc. v. Malipot; New Filipino Maritime Agencies, Inc. v. Datayan.)
  • Burden of proof: Claimant must prove by substantial evidence that the death is work-related; employer bears the burden to prove death resulted from the seafarer’s willful act to defeat compensability. (Cited: POEA-SEC Section 20; New Filipino Maritime Agencies, Inc. v. Datayan.)
  • Evidence relied upon: The Labor Arbiter and the NLRC based their findings on:
    1. Ulsan City Hospital Medical Certificate of Death signed by Dr. Sung Yeoul Hung indicating “Intentional Self-Harm by [Hanging], Strangulation and Suffocation” and noting blood loss.
    2. INTECO Investigation Report recounting scene details (shower hose, wrist cut, scissors), autopsy witnessed by Ulsan Maritime Police and company representatives, and concluding suicide.
    3. Crew statements and management investigation indicating no signs of foul play and possible motive.
  • Evaluation of CA’s criticisms: The CA emphasized alleged contradictions between the Medical Certificate (hanging) and INTECO (wrist cut) and questioned INTECO’s authority. The Supreme Court found these distinctions immaterial because both documents point to intentional self-harm (suicide), and the CA’s skepticism did not rise to grave abuse of discretion.
  • Admissibility and weight of evidence: Labor tribunals are not bound by strict technical rules of evidence; the NLRC may admit evidence submitted for the first time on appeal and weigh such evidence in the interest of substantial justice. Prior jurisprudence (Wallem Maritime Services v. Pedrajas; Unicol v. Malipot) recognizes foreign medico-legal and investigation reports as substantial where they coherently support suicide.
  • Conclusion: Petitioners presented substantial evidence that Ryan’s death was self-inflicted; absent incontrovertible proof to the contrary, the LA’s and NLRC’s factual findings were not arbitrary or unsupported by substantial evidence. Therefore the CA’s reversal constituted error.

Doctrine / Legal Principle

  • As claimant for death benefits, the heir must prove by substantial evidence that the death was work-related and compensable.
  • An employer may avoid liability for death benefits under POEA-SEC Section 20(D) by proving the death resulted from the seafarer’s willful or intentional act.
  • Quasi-judicial labor bodies are afforded latitude to receive and weigh evidence not governed by strict technical rules of evidence.
  • Rule 45 review is confined to determining grave abuse of discretion amounting to lack or excess of jurisdiction; conflicting findings may warrant Supreme Court review of records for legal correctness.

Disposition

  • The petition is GRANTED.
  • The Court of Appeals’ January 31, 2011 Decision and August 8, 2011 Resolution in CA-G.R. SP No. 112898 are ANNULLED and SET ASIDE.
  • The National Labor Relations Commission’s December 16, 2009 Decision in NLRC LAC OFW (M) 09-000540-09 is REINSTATED and AFFIRMED.
  • Effect: Shirley De Chavez’s claim for death benefits is denied; petitioners are not liable for death compensation under the POEA-SEC.

Concurring / Dissenting Opinions

  • Concurring: Sereno, C.J.; Leonardo-De Castro, and Tijam, JJ.
  • Jardeleza, J. was on official leave.
  • No separate dissenting opinion noted.

Significance / Notes

  • Confirms that foreign medical certificates and investigation reports may constitute substantial evidence in labor cases where they coherently support the cause of death.
  • Affirms the employer’s ability to defeat a death benefits claim by proving death was due to the seafarer’s willful act under POEA-SEC Section 20(D).
  • Reinforces the limited scope of Rule 45 review: the Supreme Court will not lightly overturn NLRC factual findings absent grave abuse of discretion.
  • Reiterates that labor tribunals are not constrained by formal evidentiary technicalities and may admit and weigh additional evidence on appeal in the interest of substantial justice.
  • Practical implication: where evidence points to suicide with corroborating medico-legal and investigative reports, death benefits under the POEA-SEC may be denied.
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