G.R. No. 151993; October 19, 2011
MARITIME FACTORS INC., Petitioner, vs. BIENVENIDO R. HINDANG, Respondent.

FACTS

Petitioner Maritime Factors Inc., a manning agency, engaged the services of Danilo R. Hindang as a seafarer on board the M/T “Reya” under a 12-month contract. On July 27, 1994, Danilo was found dead inside the locker of his cabin. Saudi Arabian authorities, through Dr. Ossman Abdel Hameed, concluded the cause of death was suicide by hanging. Danilo’s remains were repatriated to the Philippines, where an autopsy by the NBI’s Dr. Maximo L. Reyes concluded the cause of death was “Asphyxia by Strangulation, Ligature,” indicating someone caused his death. Respondent Bienvenido R. Hindang, Danilo’s brother, filed a claim for death benefits. The Labor Arbiter granted the claim, finding the NBI report credible and ruling that petitioner failed to prove suicide. The NLRC affirmed the decision. The Court of Appeals denied petitioner’s certiorari petition, upholding the NLRC’s findings. Petitioner assails the CA’s decision, arguing the Saudi medical report should have been given credence, the factual conclusion was speculative, and respondent’s relationship to the deceased was unsubstantiated.

ISSUE

Whether Danilo committed suicide during the term of his employment contract, which would exempt petitioner from paying death compensation benefits under the POEA Standard Employment Contract.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision. The Court held that the findings of fact by the Labor Arbiter, NLRC, and Court of Appeals, being supported by substantial evidence, are final and binding. Under the POEA Standard Employment Contract, the employer bears the burden of proving that a seafarer’s death resulted from a willful or criminal act to avoid liability. Petitioner failed to discharge this burden. The evidence presented by petitioner—a photocopy of a fax transmission of an alleged English translation of a Saudi medical report—was unreliable and could not be verified as to its genuineness and due execution in the Philippines. In contrast, the NBI autopsy report and certification, which concluded death was caused by strangulation (indicating foul play), were credible and constituted substantial evidence. The written report of Danilo’s fellow crew members did not conclusively prove suicide. Furthermore, petitioner was estopped from questioning respondent’s relationship to the deceased, as it had admitted this fact in its Answer to the complaint before the Labor Arbiter. Therefore, Danilo’s death is compensable.