G.R. No. L-54204 September 30, 1982
NORSE MANAGEMENT CO. (PTE) and PACIFIC SEAMEN SERVICES, INC., petitioners, vs. NATIONAL SEAMEN BOARD, HON. CRESCENCIO M. SIDDAYAO, OSCAR M. TORRES, REBENE C. CARRERA and RESTITUTA C. ABORDO, respondents.

FACTS

Napoleon B. Abordo, husband of private respondent Restituta C. Abordo, was employed as Second Engineer on the Singapore-registered vessel M.T. “Cherry Earl” by petitioner Norse Management Co. (PTE). He died from an apoplectic stroke in May 1978 during the course of his employment. In her claim before the National Seamen Board (NSB), Restituta Abordo sought death compensation benefits based on the law of Singapore, where the vessel was registered.
Petitioners, Norse Management and its local agent Pacific Seamen Services, Inc., opposed the application of Singapore law. They argued that the NSB could not take judicial notice of Singapore’s Workmen’s Insurance Law, which was neither alleged nor proven as required for foreign law. As an alternative, they offered to pay P30,000 based on NSB Memorandum Circular No. 25.

ISSUE

Whether the National Seamen Board correctly applied Singapore law in determining the death benefits due, despite the foreign law not being formally alleged and proven in the proceedings.

RULING

Yes, the NSB correctly applied Singapore law. The Supreme Court affirmed the NSB’s decision ordering petitioners to pay US$30,600 (equivalent to 36 months’ salary) as death compensation, plus funeral expenses and attorney’s fees.
The legal logic is grounded on the nature and policy of administrative quasi-judicial bodies. While it is a general rule in regular courts that foreign laws must be pleaded and proved as facts, this technical rule of evidence is not strictly binding on administrative agencies like the NSB. The Court emphasized that such bodies are not constrained by technical procedural rules and are permitted to utilize their specialized knowledge. The NSB, by virtue of its original and exclusive jurisdiction over overseas seafarer employment disputes, could properly take cognizance of pertinent Singapore maritime compensation laws.
Furthermore, the Court upheld the NSB’s established policy of applying the law of the vessel’s registry in compensation claims, a policy designed to ensure adequate protection for Filipino seamen. Any doubt in the interpretation of labor legislation must be resolved in favor of labor. The petitioners’ offer based on a local memorandum circular was correctly rejected, as the employment contract and the governing policy pointed to the application of the foreign law for the registered vessel.