G.R. No. 178564 , January 15, 2014
INC Shipmanagement, Inc., Captain Sigfredo E. Monterroyo and/or Interorient Navigation Limited, Petitioners, vs. Alexander L. Moradas, Respondent.

FACTS

Respondent Alexander Moradas was employed as a wiper aboard the MV Commander. On October 13, 2000, he claimed an explosion in the ship’s incinerator caused chemicals to splash on him, resulting in thermal burns. He was treated and later repatriated. Diagnosed with 11% second and third-degree burns, his physician estimated full healing within three to four months. Moradas, however, claimed permanent total disability and demanded US$60,000 in benefits under the POEA-SEC.
Petitioners INC Shipmanagement and Interorient Navigation countered that the injury was self-inflicted and non-compensable. They alleged that days prior, Moradas was caught stealing ship supplies and was informed of his impending dismissal. They presented affidavits from crew members stating there was no fire in the incinerator at the time, that Moradas soaked his hands in paint thinner, and that he set himself ablaze. They argued this was an attempt to sabotage the vessel or fabricate a compensable claim following his disciplinary issues.

ISSUE

Whether respondent Alexander Moradas is entitled to permanent total disability benefits under the POEA-SEC, or whether his injury is non-compensable for being self-inflicted.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ award of disability benefits to Moradas. The legal logic centered on the burden of proof and the presumption of compensability under the POEA-SEC. For an injury to be deemed self-inflicted under Section 20(D) of the contract, the employer must present substantial evidence to overcome the presumption that the seafarer’s illness or injury is work-related.
The Court found petitioners’ evidence insufficient to prove self-infliction. The affidavits of the crew, while numerous, were deemed suspect as they were executed only after the filing of the complaint and were not subjected to cross-examination. Their claims that Moradas set himself on fire were considered inconsistent with human experience and natural instinct. Furthermore, the alleged motive—stealing supplies and fear of dismissal—was not convincingly established. In contrast, Moradas consistently maintained his version of an accidental explosion. Consequently, petitioners failed to discharge their burden of proof. The injury was therefore compensable, and Moradas was entitled to the maximum disability benefit for permanent total disability as his injury resulted in his inability to work as a seaman for more than 120 days.