G.R. No. 175491; December 10, 2012
CREW AND SHIP MANAGEMENT INTERNATIONAL INC. and SALENA INC., Petitioners, vs. JINA T. SORIA, Respondent.
FACTS
Zosimo Soria was employed as an Assistant Cook by petitioners. On June 5, 1996, he suffered a burn on his left knee from brushing against a hot engine. He received initial treatment on board. On June 28, 1996, he sought further medical attention, underwent skin grafting in Ecuador, and was declared fit for repatriation on July 10, 1996. Upon returning to the Philippines, he reported to the company-designated clinic on July 19, 1996, where his wound was noted as dry and non-infected, though with slight difficulty in flexing the knee. Zosimo died on July 31, 1996. The Medico-Legal Report and Death Certificate stated the cause of death as “Pneumonia with Congestion of all visceral organs.”
Respondent Jina Soria, Zosimo’s widow, filed a claim for death benefits, alleging he died from tetanus resulting from the burn injury. The Labor Arbiter dismissed the complaint, finding the death was due to pneumonia, not the work-related burn, and that the employment contract had already terminated. The NLRC initially reversed this, ruling the death was compensable as pneumonia could be a complication of tetanus from the burn. Upon reconsideration, the NLRC reinstated the Labor Arbiter’s dismissal. The Court of Appeals then set aside the NLRC and granted the claim, prompting this petition.
ISSUE
Whether the death of Zosimo Soria is compensable under the POEA Standard Employment Contract.
RULING
Yes, the death is compensable. The Supreme Court affirmed the Court of Appeals. For death to be compensable, it is sufficient that the work-related injury or illness contributed to the death, even if not the sole cause. The Court found a reasonable causal connection between the burn injury and the fatal pneumonia. Medical authorities establish that severe burns compromise the skin barrier, increasing susceptibility to systemic infections, including pneumonia. The timeline was significant: Zosimo sustained the burn during his contract, required extensive skin grafting, and died just weeks after repatriation. The company-designated physician’s final report did not declare him fit to work but noted ongoing issues, meaning his medical treatment was not concluded.
Petitioners failed to substantiate their claim that the pneumonia was contracted locally and was unrelated to the burn. They bore the burden to prove a supervening event that severed the causal link, which they did not. The cause of death stated on the certificate is not conclusive; the surrounding circumstances must be considered. The proximity between the injury, the medical complications, and the death, without proof of an intervening cause, supports compensability. Therefore, the presumption of work-relatedness and compensability under the contract was not overturned.
