GR 190534; (February, 2016) (Digest)
G.R. No. 190534 February 10, 2016
C.F. SHARP CREW MANAGEMENT, INC., RONALD AUSTRIA, and ABU DHABI NATIONAL TANKER CO., Petitioners, vs. LEGAL HEIRS OF THE LATE GODOFREDO REPISO, represented by his wife LUZVIMINDA REPISO, Respondents.
FACTS
Godofredo Repiso was hired as a messman by C.F. Sharp Crew Management, Inc. for its principal, Abu Dhabi National Tanker Co. He underwent a pre-employment medical examination (PEME) and was declared fit. He commenced work on May 20, 2002. He was repatriated to the Philippines on March 16, 2003. On March 17, 2003, he was diagnosed with essential hypertension. On March 19, 2003, he suffered a fatal heart attack. His death certificate listed the causes as irreversible shock, acute myocardial infarction, and hypertensive heart disease. His heirs filed a claim for death benefits, burial allowance, and children’s allowances against the petitioners.
ISSUE
Whether the heirs of the deceased seafarer are entitled to death benefits and other monetary claims under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).
RULING
Yes, the heirs are entitled to the claims. The applicable contract is the 1996 POEA-SEC, as the 2000 POEA-SEC was under a temporary restraining order at the time of contract execution. Under the 1996 POEA-SEC, for death to be compensable, it is sufficient that it occurs during the term of the employment contract. The Court emphasized that the contract is designed to protect seafarers, and its provisions are construed liberally in their favor. Godofredo’s death occurred within three days of his repatriation, which was indisputably during the term of his contract. The petitioners’ argument that his illness was pre-existing and concealed was rejected. The PEME is not exploratory and does not preclude compensability for illnesses that manifest during employment. The Court also noted that the mandatory three-day post-employment medical examination requirement is for claims of sickness allowance, not for death benefits. Since the death was compensable under the 1996 POEA-SEC, the heirs are entitled to death benefits, burial allowance, and children’s allowances as stipulated. The Labor Arbiter’s award was reinstated.