G.R. No. 206562 January 21, 2015
UNICOL MANAGEMENT SERVICES, INC., LINK MARINE PTE. LTD. and/or VICTORIANO B. TIROL, III, Petitioners, vs. DELIA MALIPOT, in behalf of GLICERIO MALIPOT, Respondent.

FACTS

The deceased seaman, Glicerio Malipot, was hired by petitioner Unicol Management Services, Inc. for its principal, Link Marine Pte. Ltd., as Chief Engineer Officer on the vessel Heredia Sea under a POEA-approved contract with a duration of four months and a monthly salary of $2,500. He underwent a pre-employment medical examination and was found fit to work. He departed on August 18, 2008. Respondent Delia Malipot, his surviving spouse, alleged that her husband suffered emotional strain after petitioners refused his request to be repatriated before the end of his contract, with the Port Captain threatening him with arrest and blacklisting. He became depressed, experienced chest pains, and was diagnosed with “Muscoskeletal pain and Emotional trauma/illness” at a medical center in Fujairah, UAE. He was not repatriated even after his contract allegedly expired on December 18, 2008. On January 13, 2009, petitioners reported that Glicerio committed suicide by hanging on the vessel. This was supported by a Medico Legal Report and a Death Certificate from UAE authorities. Respondent filed a complaint for death benefits. The Labor Arbiter awarded death compensation, attorney’s fees, and burial expenses, ruling petitioners failed to substantially prove suicide. The NLRC reversed the Labor Arbiter, dismissing the complaint and holding the death was due to non-compensable suicide based on the foreign documents. The Court of Appeals then reversed the NLRC, reinstating the award, holding petitioners failed to prove the circumstances leading to the suicide.

ISSUE

Whether the death of seaman Glicerio Malipot is compensable under the POEA Standard Employment Contract.

RULING

The Supreme Court REVERSED and SET ASIDE the Decision of the Court of Appeals and REINSTATED the Decision of the NLRC. The Court held that the death was not compensable. It found that petitioners sufficiently established through substantial evidence—specifically the Medico Legal Report, Death Certificate, and a Certification from the Philippine Consulate—that the seaman’s death was caused by suicide. The Court ruled that suicide is not a compensable work-related illness or injury under the POEA contract. It emphasized that the burden to prove compensability, i.e., that the death was work-related, rested on the claimant. The Court found that respondent failed to substantiate her claim that the suicide was caused by work-related stress or the employer’s actions. The foreign documents, being public documents issued by competent authority, were accorded probative value. The Court further held that the NLRC’s factual findings, which were supported by evidence, are generally accorded respect and finality.