G.R. No. 77828 February 8, 1989
EASTERN SHIPPING LINES, INC., petitioner, vs. PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION, SECRETARY OF LABOR AND EMPLOYMENT, HEARING OFFICER CHERYL AMPIL and MA. LOURDES A. ZARAGOZA, respondents.

FACTS

Manuel Zaragoza, a long-time employee of Eastern Shipping Lines, Inc., died of myocardial infarction on September 18, 1983, while serving as Chief Engineer aboard the M/V Eastern Meteor in Japan. The vessel was foreign-owned but chartered by Eastern and registered in Panama. On December 17, 1985, his widow, Ma. Lourdes Zaragoza, filed a complaint with the Philippine Overseas Employment Administration (POEA) claiming death benefits under NSB Memorandum Circular No. 71, alleging entitlement to P100,000.00 as the vessel was Panamanian-registered.
Eastern Shipping contested the POEA’s jurisdiction, arguing it was not engaged in overseas employment and that the claim should be filed with the Social Security System. It also asserted that the M/V Eastern Meteor was considered a vessel of Philippine registry and that it had already paid P17,000.00 in benefits. The POEA rendered a decision on March 19, 1987, ordering Eastern to pay an additional P88,000.00 as the unpaid balance of the death benefits. Eastern filed a petition directly with the Supreme Court.

ISSUE

The primary issues are: (1) whether the POEA has jurisdiction over the widow’s claim for death benefits; and (2) whether the applicable death benefit is governed by NSB Memorandum Circular No. 71 for foreign-registered vessels.

RULING

The Supreme Court dismissed the petition and affirmed the POEA’s decision. On jurisdiction, the Court held that the POEA has original and exclusive jurisdiction over the money claim. Executive Order No. 797 and its implementing rules explicitly grant the POEA jurisdiction over all cases involving employer-employee relations arising from the overseas employment of Filipino workers, including seamen. The deceased was employed under a contract with Eastern, working on an ocean-going vessel in international waters, which constitutes overseas employment. The fact that Eastern submitted its shipping articles to the POEA for processing further indicated its recognition of the POEA’s regulatory authority over such employment.
On the applicable benefits, the Court upheld the POEA’s application of Section D, paragraph 1 of NSB Memorandum Circular No. 71, which provides a P100,000.00 death benefit for seamen on foreign-registered vessels. The Court interpreted the circular’s provisions: paragraph 1 covers seamen on foreign-registered vessels, while paragraph 2 covers those on Philippine-registered vessels, except those foreign-owned and bareboat-chartered to a Philippine company. The M/V Eastern Meteor, being foreign-owned and Panamanian-registered (even if also registered in the Philippines), falls under the exception in paragraph 2 and is therefore governed by paragraph 1. The regulatory policy ensures uniform benefits for Filipino seamen on ocean-going vessels regardless of the vessel’s nationality. Thus, the widow was correctly awarded the P100,000.00 benefit, minus the amount already paid by Eastern.