G.R. No. 202859, November 11, 2015
NEW FILIPINO MARITIME AGENCIES, INC., TAIYO NIPPON KISEN CO., LTD., AND ANGELINA T. RIVERA, PETITIONERS, VS. VINCENT H. DATAYAN – HEIR OF SIMON VINCENT H. DATAYAN III, RESPONDENT.

FACTS

Simon Vincent Datayan II was employed as a deck cadet by New Filipino Maritime Agencies, Inc. on behalf of St. Paul Maritime Corp. on August 8, 2007. He was declared fit for sea duties after a pre-employment medical examination. On December 30, 2007, during an emergency fire drill, the Master reported that Simon jumped overboard. A search-and-rescue operation was conducted, but Simon was declared missing and presumed dead. His father, Vincent H. Datayan (respondent), filed a complaint for death benefits and attorney’s fees against the petitioners (the agency, the vessel manager, and a company officer). The respondent argued that death during employment entitled him to benefits under the collective bargaining agreement (CBA) and that the petitioners were presumed negligent. The petitioners defended that Simon’s death resulted from his own willful act—suicide—as evidenced by a suicide note found on the vessel, the Master’s Report, a Marine Note of Protest, and an Investigation Report, thus exempting them from liability under the POEA Standard Employment Contract. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the complaint, finding the suicide established. The Court of Appeals reversed, awarding death benefits, damages, and attorney’s fees to the respondent, holding that the petitioners failed to prove suicide with substantial evidence and that the death was compensable.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and awarding death benefits to the respondent, despite findings that the seafarer’s death was due to his own willful act (suicide), which would exempt the employer from liability under the POEA Standard Employment Contract.

RULING

The Supreme Court GRANTED the Petition, REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals, and REINSTATED and AFFIRMED the NLRC Decision dismissing the complaint. The Court held that the employer may be exempt from liability for death benefits if it can establish that the seafarer’s death was attributable to his own willful act. The Labor Arbiter and the NLRC correctly found, based on substantial evidence, that Simon committed suicide. The evidence included a suicide note (whose authenticity was affirmed by comparing the signature with that on his POEA contract), the Master’s Report, a Marine Note of Protest, and an Investigation Report. These documents were official, notarized, and authenticated. The Court found the CA erred in disregarding this evidence and in awarding damages and attorney’s fees, as the petitioners’ denial of the claim was in good faith, supported by evidence and investigation. The death was not compensable under Section 20(D) of the POEA Standard Employment Contract, which excludes benefits for death resulting from a seafarer’s willful act.