G.R. No. 183646 ; September 18, 2009
GREAT SOUTHERN MARITIME SERVICES CORP. and IMC SHIPPING CO., PTE. LTD., Petitioners, vs. LEONILA SURIGAO for Herself and In Behalf of Her Minor Children, Namely KAYE ANGELI and MIRIAM, Both Surnamed SURIGAO, Respondents.

FACTS

Salvador M. Surigao was hired as a Fitter by petitioner Great Southern Maritime Services Corporation for its principal, IMC Shipping Co., Pte. Ltd. He commenced work on April 29, 2001, aboard MV Selendang Nilam. In August 2001, due to a worsening skin condition, he was medically attended to and subsequently confined at Seven Hills Hospital. The Ship Master signed him off on August 25, 2001, for treatment and repatriation. The following morning, on August 26, 2001, Salvador was found dead inside his hospital bathroom. A Post-Mortem Certificate from Visakhapatnam City stated the cause of death as “asphyxia due to hanging.”
Respondent Leonila Surigao, Salvador’s widow, filed a claim for death benefits under the POEA Standard Employment Contract. The Labor Arbiter granted the claim, ordering petitioners to pay US$71,500. The National Labor Relations Commission (NLRC) reversed this decision, finding the death non-compensable but awarding US$5,000 as financial assistance. The Court of Appeals subsequently reinstated the Labor Arbiter’s decision, prompting this petition.

ISSUE

Whether the heirs of Salvador Surigao are entitled to death benefits under the POEA Standard Employment Contract, considering the cause of death was “asphyxia due to hanging.”

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the NLRC decision, denying the claim for death benefits. The legal logic centers on the application of Section 20(D) of the POEA contract, which states no compensation is payable for death resulting from the seafarer’s “willful or criminal act,” provided the employer can prove such death is directly attributable to the seafarer.
The Court held that the employer successfully discharged this burden of proof. The Post-Mortem Certificate, which was unrebutted by the respondent, conclusively established the cause of death as “asphyxia due to hanging.” This finding inherently implies a deliberate, self-inflicted act. The Court rejected the respondent’s argument that the death could have been accidental, noting the complete absence of evidence—such as signs of struggle, foul play, or a suicide note—to support an alternative theory. In the face of the official medical finding, mere speculation or the family’s disbelief could not overturn the factual conclusion. Consequently, the death was directly attributable to Salvador’s own willful act, falling under the contractual exemption from liability. The grant of financial assistance by the NLRC, while not obligatory, was a gesture of compassion that the Court saw no reason to disturb.