Heirs of Aniban v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Brigida P. Aniban, representing the heirs of the late Reynaldo Aniban, assailed the decision of the National Labor Relations Commission (NLRC) which reversed the Philippine Overseas Employment Administration (POEA) ruling. The POEA had declared myocardial infarction as an occupational disease for R/O Reynaldo Aniban and awarded death benefits totaling US$67,000.00, plus attorney's fees of US$6,700.00. Reynaldo Aniban was employed as a radio operator by Philippine Transmarine Carriers, Inc. (TRANSMARINE) for its foreign principal, Norwegian Ship Management A/S (NORWEGIAN), and died due to myocardial infarction during his contract period. His heirs claimed death benefits under the POEA Standard Employment Contract (US$13,000.00) and the Collective Bargaining Agreement (CBA) (US$30,000.00 plus US$24,000.00 for three minor children). Procedural History: The POEA granted the claim, ruling that myocardial infarction was an occupational disease and awarding the full amounts claimed, including attorney's fees. On appeal, the NLRC reversed the POEA, denying the additional death benefits under the CBA and asserting that the Employees Compensation Commission (ECC) had original and exclusive jurisdiction. The NLRC's denial of a motion for reconsideration led to the present petition. The Petition: The heirs of R/O Reynaldo Aniban filed a petition before the Supreme Court, raising two issues: (a) the jurisdiction of the POEA to determine the claim for death benefits, and (b) whether myocardial infarction is an occupational disease entitling them to benefits under the CBA.
Issue(s)
Whether the POEA has jurisdiction to determine the claim for death benefits. Whether myocardial infarction is an occupational disease entitling the heirs to death benefits under the CBA.
Ruling
The Supreme Court reversed and set aside the assailed Decision and Resolution of the NLRC. It reinstated the Decision of the POEA, ordering the respondents to pay the heirs of R/O Reynaldo Aniban the death benefits under the POEA Standard Employment Contract and the CBA, as well as additional compensation for the children. The award for attorney's fees was modified to P50,000.00.
Ratio Decidendi
On the jurisdiction of the POEA: The Court held that the POEA has original and exclusive jurisdiction over all matters or cases, including money claims, involving employer-employee relations arising out of or by virtue of any law or contract involving Filipino seamen for overseas employment, as provided by Art. 20 of the Labor Code as amended by E.O. Nos. 797 and 247. The jurisdiction of the ECC is limited to appellate functions over decisions of the GSIS or SSS and does not extend to original jurisdiction over claims of overseas contract workers. Therefore, the NLRC's ruling that the ECC had exclusive jurisdiction constituted grave abuse of discretion. On whether myocardial infarction is an occupational disease: The Court affirmed the POEA's finding that myocardial infarction was an occupational disease in the case of R/O Aniban. It noted that Aniban was healthy when he boarded the vessel and had no prior health problems except for a defective central vision, for which he was certified fit to work. His death due to myocardial infarction occurred three months into his employment. The Court recognized that the pressure and strain of the job, coupled with the stress of being away from his pregnant wife, aggravated his condition, making it occupational. The Court reiterated that death due to myocardial infarction is compensable and that strict rules of evidence are not applicable in compensation proceedings, where probability, not certainty, is the test of proof. The Court also took judicial notice of the emotional strain overseas workers, especially seamen, endure, which can contribute to such conditions.
Main Doctrine
The Philippine Overseas Employment Administration (POEA) has original and exclusive jurisdiction over all matters or cases involving employer-employee relations, including money claims, arising out of or by virtue of any law or contract involving Filipino seamen for overseas employment. The Employees Compensation Commission (ECC) only exercises appellate jurisdiction over decisions of the GSIS or SSS, and not original jurisdiction over claims of overseas contract workers.