Unicol Management Services v. Malipot
REITERATIONFacts
The Antecedents: Respondent Delia Malipot is the surviving spouse of deceased seaman Glicerio Malipot. Seaman Glicerio was hired by petitioner Unicol Management Services, Inc. (Unicol), for its principal Link Marine Pte. Ltd. (Link Marine), as Chief Engineer Officer on the vessel Heredia Sea for a four-month contract. He was found fit to work during pre-employment medical examination. Seaman Glicerio allegedly suffered emotional strain due to petitioners' refusal to allow him to go home, despite expressing his desire to end his contract as early as November 16, 2008. He was allegedly threatened by the Port Captain with arrest and blacklisting if he left the vessel. He became ill with chest pains and palpitations, diagnosed with Musculoskeletal pain and Emotional trauma/illness, but was not repatriated. His contract expired on December 18, 2008, but he remained on board. Procedural History: On January 13, 2009, petitioners received information that seaman Glicerio committed suicide by hanging in the store room of the Heredia Sea, confirmed by reports from the Philippine Consulate General at Dubai, the Medico-Legal Report, and the Death Certificate from the United Arab Emirates. Respondent filed a complaint for death compensation. The Labor Arbiter awarded death benefits, burial expenses, and attorney's fees, ruling that petitioners failed to prove suicide with substantial evidence. The National Labor Relations Commission (NLRC) reversed this, finding that seaman Glicerio committed suicide and that it was not compensable under the POEA contract. The Court of Appeals (CA) reinstated the Labor Arbiter's decision, holding that petitioners failed to prove the circumstances leading to the suicide and that the consideration for a quitclaim executed by respondent was inordinately low. The CA ordered the deduction of the amount received from the award. The Petition: Petitioners filed a petition for review on certiorari, arguing that the CA erred in disregarding the evidence proving suicide and in ruling that suicide is compensable. The main issue is whether seaman Glicerio committed suicide during his contract, thereby exempting petitioners from paying death compensation benefits.
Issue(s)
Whether the Court of Appeals erred in its ruling that there was no showing that petitioners exerted efforts to ascertain the circumstances surrounding seaman Glicerio's death. Whether death by suicide is compensable under the POEA Contract, and the conditions under which such compensation is not payable. Whether seaman Glicerio committed suicide during the term of his employment contract, based on the available evidence.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals decision, and reinstated the National Labor Relations Commission's decision dismissing the complaint for lack of merit. The Court ruled that seaman Glicerio's death was attributable to his deliberate act of suicide and therefore not compensable under the POEA Standard Employment Contract.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in its ruling that there was no showing that petitioners exerted efforts to ascertain the circumstances surrounding seaman Glicerio's death: The Supreme Court held that the CA erred in disregarding the evidence submitted by petitioners on appeal to the NLRC, such as the Investigation Report, log book extracts, and Master's Report. The NLRC is allowed to receive evidence submitted for the first time on appeal to ascertain facts objectively and speedily in the interest of substantial justice, as rules of evidence in courts are not controlling in labor cases. These reports, along with the Medico-Legal Report and Death Certificate, substantially proved that seaman Glicerio's death was attributable to his deliberate act of suicide. On the issue of whether death by suicide is compensable under the POEA Contract: The Supreme Court clarified that while the employer is liable for death benefits if a seafarer dies during his contract, they may be exempt if they can prove the death was caused by an injury directly attributable to the seafarer's willful or criminal act or intentional breach of duties. Section 20(D) of the POEA Standard Employment Contract explicitly states that no compensation and benefits shall be payable in respect of death resulting from the seafarer's willful or criminal act or intentional breach of his duties, provided the employer can prove such direct attribution. In this case, the employer successfully proved that the death was directly attributable to the seafarer's deliberate act. On the issue of whether seaman Glicerio committed suicide during the term of his employment contract: The Supreme Court found that the evidence substantially proved that seaman Glicerio committed suicide. The Medico-Legal Report issued by the United Arab Emirates Ministry of Justice concluded that the death was due to "suicidal asphyxia due to hanging." The external examination of the body showed no signs of violence or resistance, supporting the finding of suicide. This conclusion was bolstered by the Investigation Report, log book extracts, and Master's Report, which detailed the events leading to his death, including his expressed family problems and desire to go home, and his subsequent withdrawal. The diagnosis of emotional trauma due to family problems further supported the circumstances leading to his death.
Main Doctrine
Death by suicide is not compensable under the POEA Standard Employment Contract if the employer can substantially prove that the seafarer's death is directly attributable to his deliberate act of killing himself.