G.R. No. 166803 ; October 11, 2012
CREWLINK, INC. and/or GULF MARINE SERVICES, Petitioners, vs. EDITHA TERINGTERING, for her behalf and in behalf of minor EIMAEREACH ROSE DE GARCIA TERINGTERING, Respondents.

FACTS

Respondent Editha Teringtering, on behalf of herself and her minor child, filed a complaint against petitioners Crewlink, Inc. and Gulf Marine Services for death and other benefits following the death of her husband, Jacinto Teringtering, an oiler. Jacinto died by drowning on April 9, 2001, during the term of his employment contract. The ship captain’s report indicated that Jacinto had jumped into the sea twice on the night of the incident, with the second jump resulting in his death. The respondent claimed the death was compensable, arguing it occurred during the contract and was not deliberate but a result of a psychotic disorder (Mood Disorder Bipolar Type) that compelled him to jump. Petitioners refused payment, contending the death was due to suicide, a deliberate act excluding it from compensability, and noted they had provided some burial assistance.

ISSUE

Whether the death of Jacinto Teringtering is compensable under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC), notwithstanding the circumstances of him jumping into the sea.

RULING

The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals and reinstating the decisions of the NLRC and Labor Arbiter which denied the claim. The legal logic centers on the burden of proof and the application of the POEA-SEC provisions on compensability. For death to be compensable under the contract, it must not be due to the seafarer’s deliberate or intentional act. The factual findings from the ship captain’s report, which detailed two separate jumps, established a prima facie case that the death resulted from a deliberate act. The burden then shifted to the respondent to prove by substantial evidence that Jacinto was suffering from a mental disorder that negated the voluntariness of his act, rendering it not a deliberate suicide. The Court found the respondent failed to meet this burden. Her claim of insanity was unsupported by any medical evidence, expert testimony, or even testimony from persons intimately acquainted with Jacinto’s mental state. Mere allegation, without proof, is insufficient. Consequently, the death was deemed a result of a deliberate act and thus non-compensable. The Court emphasized that while labor contracts are construed liberally in favor of seafarers, justice must be dispensed according to established facts and evidence.