G.R. No. 168715 ; September 15, 2010
MEDLINE MANAGEMENT, INC. and GRECOMAR SHIPPING AGENCY, Petitioners, vs. GLICERIA ROSLINDA and ARIEL ROSLINDA, Respondents.

FACTS

Petitioners Medline Management, Inc. and Grecomar Shipping Agency hired Juliano Roslinda as a seafarer. His latest POEA-approved contract ended upon his discharge and repatriation on January 20, 2000. Months later, on March 6, 2000, Juliano sought medical consultation for abdominal distention and subsequently underwent treatment, including hemodialysis. He died on August 27, 2001. On September 4, 2003, his heirs, respondents Gliceria and Ariel Roslinda, filed a complaint for death benefits and other claims before the NLRC. Petitioners moved to dismiss on grounds of prescription, lack of jurisdiction due to alleged absence of an employer-employee relationship at the time of death, and prematurity for failure to utilize the grievance machinery. The Labor Arbiter denied the motion, a ruling affirmed by the NLRC and the Court of Appeals.

ISSUE

The primary issue is whether the heirs of a seafarer are entitled to death benefits under the POEA Standard Employment Contract when the seafarer dies after the termination of his employment contract.

RULING

The Supreme Court denied the petition. On the procedural issue, the Court held that the Labor Arbiter’s order denying the motion to dismiss was indeed not appealable, as per NLRC rules, and the CA correctly sustained this. On the substantive claim for death benefits, the Court ruled that entitlement is governed strictly by the POEA-SEC. For death to be compensable, it must occur during the term of the employment contract. The contract is the law between the parties. Juliano’s contract had unequivocally terminated upon his repatriation on January 20, 2000. His death occurred over a year and seven months later, on August 27, 2001, well beyond the contract’s effectivity. The Court emphasized that while it construes the contract liberally in favor of seafarers, this cannot override its clear terms. There was no evidence presented that Juliano’s illness was contracted during his employment or that his working conditions increased the risk of contracting his fatal illness. Consequently, since the death occurred after the contract term, the legal basis for claiming compensation under the POEA-SEC does not exist. The claim, therefore, while not barred by prescription, fails on its merits due to the absence of the requisite condition that the death happen within the employment period. The Labor Arbiter was directed to dismiss the complaint.