G.R. No. 198225 . September 27, 2017
TSM SHIPPING (PHILS.), INC., AND MST MARINE SERVICES PHILS., INC., PETITIONERS, VS. SHIRLEY G. DE CHAVEZ, RESPONDENT.

FACTS

Petitioners hired Ryan Pableo De Chavez as chief cook on board the vessel Haruna Express. On February 26, 2006, during the contract’s effectivity, Ryan was found dead inside his locked cabin bathroom, hanging by a shower cord and with a cut wrist. Respondent Shirley De Chavez, Ryan’s widow, filed a complaint for death benefits, arguing the death was compensable as it occurred during employment. She contended Ryan did not commit suicide, citing his recent promotion, new marriage and home, a prior normal medical check-up, and the absence of a suicide note. She also questioned the inconsistency between the foreign hospital’s medical certificate citing “hanging” and a private investigation report citing “excessive bleeding.”
Petitioners resisted the claim, asserting Ryan’s death was a suicide excluded from compensation under the POEA-SEC. They relied on the Medical Certificate of Death from Ulsan City Hospital in Korea, written statements from the ship’s officers and a messmate, and an investigation report by INTECO, all concluding suicide. They suggested a motive involving familial pressure to secure a loan. The Labor Arbiter and the NLRC dismissed the complaint, finding the evidence sufficient to establish suicide.

ISSUE

Whether the Court of Appeals erred in granting death benefits by finding insufficient evidence to prove that the seafarer’s death was due to suicide.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the NLRC Decision, ruling that petitioners successfully discharged their burden of proving the death resulted from an excluded cause under the employment contract. The legal logic hinges on the application of the burden of proof in claims for death benefits under the POEA-SEC. While the death of a seafarer during the term of his contract gives rise to a presumption that it is work-related and compensable, this presumption is disputable. The employer may rebut it by substantial evidence that the cause of death falls within the contractual exclusions, such as suicide.
Here, the Court found the totality of the evidence presented by the petitioners constituted substantial evidence to overcome the presumption. The Medical Certificate of Death, although stating “hanging” as the cause, was consistent with the physical discovery of the body. The sworn statements of the shipmaster, chief mate, and messmate, who were first on the scene, uniformly indicated a locked door, no signs of struggle, and the manner of death. The INTECO report, while a private investigation, corroborated these findings. The Court emphasized that technical rules of evidence are not strictly applied in labor proceedings, and the NLRC’s factual findings, when supported by evidence, are accorded respect. The alleged inconsistencies in the reports were minor and did not dismantle the coherent conclusion of suicide. Since the employer proved the death was due to an excluded cause, the claim for death benefits was correctly denied.