G.R. No. 191034, October 1, 2014
AGILE MARITIME RESOURCES INC., ATTY. IMELDA LIM BARCELONA and PRONAV SHIP MANAGEMENT, INC., Petitioners, vs. APOLINARIO N. SIADOR, Respondent.

FACTS

On December 18, 2000, Dennis Siador, son of respondent Apolinario Siador, entered into a seven-month employment contract as an Ordinary Seaman with petitioner Agile Maritime Resources, Inc., the local manning agent of petitioner Pronav Ship Management, Inc. On June 28, 2001, while the vessel was cruising towards Sodegaura, Japan, Dennis fell overboard and died; his body was never recovered. Apolinario filed a complaint for death benefits, damages, and attorney’s fees against the petitioners, claiming entitlement under the POEA-SEC (US$50,000) and the upgraded benefits under the ITF-TCC Collective Bargaining Agreement (US$60,000). The petitioners did not deny the incident but contended, based on the “Master’s Statement,” that Dennis jumped overboard, witnessed by Able Seaman Gil Tamayo, and made no effort to swim towards a life ring, suggesting suicide. The Labor Arbiter dismissed the complaint, finding Dennis took his own life due to heavy personal and psychological problems, a ruling affirmed by the NLRC. The Court of Appeals partially granted Apolinario’s petition, reversed the labor tribunals, and awarded US$60,000 in death benefits, citing the “Statement on Mr. Dennis Siador” signed by Filipino crewmembers that described Dennis as disturbed, anxious, depressed, and restless days before the incident, thus casting doubt on the willfulness of his act.

ISSUE

Whether the Court of Appeals correctly found that the NLRC gravely abused its discretion in holding that substantial evidence existed to support its conclusion that Dennis Siador willfully took his own life, thereby disqualifying his beneficiary from death benefits under the POEA-SEC.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the decision and resolution of the Court of Appeals. The Court held that the NLRC did not commit grave abuse of discretion. As the claimant, Apolinario had the burden of proof to establish that Dennis’s death was work-related and occurred during the employment term, which he discharged. However, under Section 20(D) of the POEA-SEC, the employer may be exempt from liability if it proves the seafarer’s death resulted from his willful or criminal act. The petitioners successfully shifted the burden of evidence to Apolinario by presenting the Master’s Statement and the Crewmembers’ Statement, which indicated Dennis’s unusual behavior and his jump overboard without attempting to reach the life ring. Apolinario failed to rebut this evidence with clear and convincing proof that Dennis was insane or mentally ill at the time of the incident. The Crewmembers’ Statement, while noting Dennis was depressed and wanted to be alone, did not establish insanity but rather suggested he was troubled by personal problems. The principle that self-destruction is not presumed does not apply where, as here, evidence points to suicide. Thus, the NLRC’s finding was supported by substantial evidence, and no grave abuse of discretion attended its ruling.