Eastern Shipping Lines, Inc. v. Philippine Overseas Employment Administration
REITERATIONFacts
The Antecedents: Francisco Urbiztondo was hired for the duration of the voyage of the vessel Eastern Galaxy, commencing November 9, 1985. He was disembarked for treatment on December 13, 1985, and subsequently died. The Philippine Overseas Employment Administration (POEA) awarded death and burial benefits to the private respondent, Angeles J. Urbiztondo. Procedural History: The POEA decision awarded P180,000.00 for burial allowances and P198,000.00 for death compensation and burial allowance, finding Section 1 Part 11 of the POEA Standard Format, as amended by Memorandum Circular No. 2, applicable. The POEA asserted jurisdiction over the claim. The Petition: Eastern Shipping Lines, Inc. (petitioner) challenged the POEA's decision, contending that the POEA lacked jurisdiction over the employee's claim, which should have been filed with the Social Security System and charged to the State Insurance Fund.
Issue(s)
Whether the Philippine Overseas Employment Administration (POEA) has jurisdiction over the claim for death and burial benefits of an overseas contract worker. Whether Memorandum Circular No. 2, amending the POEA Standard Format, is a valid administrative regulation. Whether the factual findings of the POEA are supported by sufficient evidence and were not arbitrarily resolved.
Ruling
The petition is DISMISSED. The challenged decision of the POEA is sustained. ACCORDINGLY, the petition is DISMISSED, with costs against the petitioner. It is so ordered.
Ratio Decidendi
On the jurisdiction of the POEA: The Court reiterated its ruling in Eastern Shipping Lines v. POEA (166 SCRA 533) that under Section 4(a) of Executive Order No. 797, the POEA, as successor to the National Seamen's Board, possesses original and exclusive jurisdiction over all cases, including money claims, involving employee-employer relations arising from laws or contracts concerning Filipino contract workers, including seamen. The petitioner's contention that the claim should have been filed with the Social Security System was thus rejected. On the validity of Memorandum Circular No. 2: The Court affirmed that Memorandum Circular No. 2, under which the award of death and burial benefits was made, is a valid administrative regulation. This regulation was adopted pursuant to a valid delegation of legislative powers granted by Executive Order No. 797. The Court noted that this issue had been categorically resolved in the earlier case involving the same parties and public respondent. On the factual findings of the POEA: The Court sustained the factual findings of the POEA, finding no sufficient showing that they were arbitrarily resolved or lacked evidentiary basis. These findings included the conclusion that the private respondent was an overseas contract worker under the petitioner's employ and was therefore entitled to the awards provided under Memorandum Circular No. 2. The Court also noted that the petitioner's shipping articles were processed by the POEA, which, in light of the established jurisdiction, deemed the deceased as an overseas contract worker and the petitioner as having engaged in overseas employment, thereby binding the petitioner to comply with POEA rules and regulations.
Main Doctrine
The Philippine Overseas Employment Administration (POEA) has original and exclusive jurisdiction over all cases, including money claims, involving employee-employer relations arising out of or by virtue of any law or contract involving Filipino contract workers, including seamen. Administrative regulations adopted pursuant to valid delegation of legislative powers are binding.