GR 94167; (January, 1991) (Digest)
G.R. No. 94167 ; January 21, 1991
Mabuhay Shipping Services, Inc. and Skippers Maritime Co., Ltd., petitioners, vs. Hon. National Labor Relations Commission (First Division) and Cecilia Sentina, respondents.
FACTS
Romulo Sentina was hired as a 4th Engineer by petitioner Mabuhay Shipping Services, Inc. for its principal, Skippers Maritime Co., Ltd., to work aboard the M/V Harmony I. On January 16, 1988, while the vessel was docked in Piraeus, Greece, Sentina returned from shore leave visibly intoxicated. He entered the messhall, took a fire axe, and challenged those present. He was pacified and led to his cabin but later returned to the messhall, became violent, and smashed a cup, hurling it at oiler Emmanuel Ero, causing injury. This provoked a fight between them, and after being separated, Sentina was taken to the hospital where he died the following day.
Private respondent Cecilia Sentina, the seaman’s widow, filed a complaint with the Philippine Overseas Employment Administration (POEA) for death benefits, burial expenses, unpaid salaries, and overtime pay. The POEA awarded the death compensation, ruling that payment only requires death during the contract term. The National Labor Relations Commission (NLRC) affirmed, holding that the death did not result from a “deliberate or willful act on his own life” as defined under the POEA contract, even if Sentina provoked the fight.
ISSUE
Whether the death of seaman Romulo Sentina, resulting from a fight he provoked while intoxicated, is compensable under the POEA Standard Employment Contract.
RULING
The Supreme Court granted the petition and set aside the decisions of the POEA and NLRC. The legal logic centers on the proper interpretation of Part II, Section C, No. 6 of the POEA Standard Format, which states that no compensation is payable for death resulting from a “deliberate or willful act on his own life by the seaman,” provided the employer can prove such death is directly attributable to him. The Court rejected the lower agencies’ narrow interpretation that this provision applies only to suicide.
The Court held that the circumstances of Sentina’s death constituted a deliberate and willful act directly attributable to him. His intoxication, unlawful aggression in challenging others with an axe, and the unprovoked attack on Ero, which naturally led to a defensive response and his subsequent death, placed his actions within the contractual exclusion. The mere occurrence of death during the contract term is not automatic grounds for compensation; the cause must be examined. By provoking the fatal altercation, Sentina’s own willful misconduct directly caused his death, exempting the employer from liability. This interpretation aligns with Article 172 of the Labor Code, which similarly limits liability for deaths occasioned by the employee’s intoxication or willful intent to injure himself or another.