G.R. No. 244361, July 13, 2020
THE HEIRS OF REYNALDO A. ANDAG, NAMELY VENERANDA B. ANDAG, JAYMARI B. ANDAG, HONEY GRACE B. ANDAG AND KIM PHILIP B. ANDAG, REPRESENTED BY THEIR ATTORNEY-IN-FACT, VENERANDA B. ANDAG, PETITIONERS, VS. DMC CONSTRUCTION EQUIPMENT RESOURCES INC., JORGE A. CONSUNJI, PRESIDENT, AND AGUSTINE B. GONZALEZ, AREA MANAGER, RESPONDENTS.

FACTS

Petitioners are the heirs of Reynaldo A. Andag, who was employed by respondent DMC Construction Equipment Resources Inc. (DMCI) as Second Mate on its tugboat. On October 18, 2013, while the tugboat was towing an overloaded barge, a recoiling rope struck Reynaldo, causing his death. DMCI later offered petitioners P200,000.00 as compensation, conditioned on their execution of a waiver and quitclaim, which they refused. Petitioners filed a complaint before the National Labor Relations Commission (NLRC) seeking death compensation/benefits, actual, moral, and exemplary damages with attorney’s fees for alleged negligence, and other monetary claims (e.g., holiday pay, service incentive leave pay, 13th month pay). DMCI defended that death benefits should be claimed from the Social Security System (SSS), that the P200,000.00 was from a voluntary accidental death insurance policy, and that all other monetary benefits had been paid. The Labor Arbiter dismissed the complaint. The NLRC affirmed but ordered DMCI to turn over the P200,000.00 insurance proceeds without condition, ruling that death benefits were payable by the State Insurance Fund (SSS) and that the claim for damages based on negligence was a tort claim cognizable by regular courts. The Court of Appeals upheld the NLRC rulings.

ISSUE

Whether the Court of Appeals correctly ruled that the NLRC did not gravely abuse its discretion in holding that: (1) petitioners’ claim for damages against DMCI is a claim based on torts cognizable by the regular courts; and (2) petitioners are not entitled to the monetary reliefs sought.

RULING

Yes, the Court of Appeals correctly ruled that the NLRC did not gravely abuse its discretion. The petition was denied.
1. On death compensation/benefits: Reynaldo was an inter-island seaman working within Philippine waters, and his employment was not covered by a POEA-Standard Employment Contract for international seafarers. Absent a specific contractual provision making the employer liable for death benefits, his death on duty is governed by the Labor Code (Articles 174, 178, 179, and 200[a]). The law intends that the employer’s obligation ends upon payment of contributions to the State Insurance Fund. Thus, liability for death benefits lies with the SSS, not DMCI.
2. On the claim for damages arising from alleged negligence: Petitioners’ allegations in their Position Paper made out a cause of action for tort (quasi-delict). While maintaining a safe workplace is ordinarily a labor issue, a claim specifically grounded on the employer’s negligence to provide a safe environment is a tort claim under the jurisdiction of regular courts. Therefore, the labor tribunals correctly declined jurisdiction over this claim.
3. On additional death benefits: The NLRC correctly ordered DMCI to turn over the P200,000.00 accidental death insurance proceeds to petitioners without any condition, as the amount had already been released to DMCI.
4. On other monetary claims: The factual findings of the labor tribunals, affirmed by the CA, that DMCI had already paid Reynaldo’s other monetary claims (e.g., wages, holiday pay) as evidenced by payslips, are binding and accorded finality. No grave abuse of discretion was committed by the NLRC.