G.R. No. 192993 , August 11, 2014
WALLEM MARITIME SERVICES, INC., and REGINALDO OBEN/WALLEM SHIPMANAGEMENT LIMITED, Petitioners, vs. DONNABELLE PEDRAJAS and SEAN JADE PEDRAJAS, Respondents.

FACTS

Petitioner Wallem Maritime Services, Inc., a manning agency, employed Hernani Pedrajas as Engine Boy on board M/V Crown Jade. In March 2005, during the contract term and while the vessel was in Italy, Hernani was found dead, hanging on the vessel’s Upper Deck B. His spouse, respondent Donnabelle Pedrajas, was informed it was a suicide. Suspecting foul play, she sought investigations by the PNP Crime Laboratory and the NBI, whose reports stated homicide could not be totally ruled out. Donnabelle filed a claim for death benefits under the POEA-SEC and the applicable CBA. Petitioners resisted the claim, asserting Hernani committed suicide due to involvement in a drug smuggling operation, which exempts them from liability under the POEA-SEC. They submitted an authenticated Forensic Report from the Italian Medical Examiner concluding suicide by hanging and noting Hernani tested positive for cocaine, along with alleged suicide notes. The Labor Arbiter ruled for petitioners, denying the claim. The NLRC reversed, awarding death benefits. The Court of Appeals affirmed the NLRC, giving less credence to the Italian Forensic Report and the suicide notes.

ISSUE

Whether Hernani Pedrajas committed suicide during the term of his employment contract, thereby exempting the petitioners from liability for death compensation benefits under Section 20(D) of the POEA-SEC.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Court of Appeals Decision and Resolution, and REINSTATED the Labor Arbiter’s Decision denying the claim for death benefits. The Court held that the petitioners successfully discharged their burden of proving that Hernani’s death resulted from his willful act of suicide, making it non-compensable. The Italian Medical Examiner’s Forensic Report, based on a personal examination of the crime scene and the body, and concluding beyond reasonable doubt that Hernani hung himself, was deemed more credible and comprehensive than the findings of the PNP and NBI, which were based on limited information and did not conduct their own autopsies. The suicide notes, whose contents led to the arrest of a crew member and the discovery of drugs, were found to be genuine. Therefore, pursuant to Section 20(D) of the POEA-SEC, no compensation is payable for a seafarer’s death resulting from a willful or criminal act.