Crewlink vs.
Teringtering
[G.R. No. 166803, 11 October 2012]
Ponente: Peralta
Petitioner: Crewlink, Inc. and/or Gulf Marine Services
Respondents: Editha Teringtering (for herself and the minor
Eimareach Rose De Garcia Teringtering)
Issue: Insanity, Contracts
FACTS:
Jacinto Teringtering, late husband of the respondent, entered into an
overseas employment contract (12 month duration) with the petitioner
Crewlink, Inc. for the position of Oiler on M/V Raja. Prior to employment,
Jacinto was subject to a medical examination, where he was declared “fit to
work.”
On 9 April 2001, Jacinto jumped overboard but was recovered by 2nd
Engineer Sudarto. After the incident, Jacinto was watched over by an A/B
personnel Ronald Arroga. While docked at the Nasr Oilfield, Jacinto
managed to jump off a second time and was recovered again, but was not
revived. Cause of death according to the certificate issued by the Ministry of
Health of the UAE was asphyxia.
Upon learning of Jacinto’s death, respondent claimed $50,000 for
death compensation, $1000 for burial expenses, the latter coming from
donations, amounts the petitioner gave to respondent though not entitled to
her. Respondent also claimed $7000 for the minor Eimreach, which was
refused.
Respondent claims that Jacinto’s death was compensable because he
had died during the term of his contract and while being on board. She also
asserted that his death was not of his own will but was a result of a mental
disorder (allegedly Mood Disorder Bipolar Type), thus, compensable.
Petitioners, however, argued that Editha was not entitled to benefits being
claimed due to Jacinto’s death being a suicide, the petitioners having no
involvement therein.
On 12 February 2002, the Labor Arbiter dismissed the case filed by
Editha for lack of merit, later affirmed by the National Labor Relations
Commission (NLRC) on 20 February 2003. Respondents brought the case to
the Court of Appeals, where the CA reversed and set aside the decision of the
NLRC on 8 July 2004. Petitioners seek reversal over CA decision.
ISSUE:
1. WON Jacinto was suffering from a mental disorder
2. WON Respondents are entitled to benefits
HELD
1.) No. There is no record showing when alleged insanity began. Insanity is a
question of fact; for it is a condition of the mind not susceptible to the usual
means of proof. Establishing the same requires the testimony of an expert,
such as a psychiatrist.
Findings of fact of administrative agencies and quasi-judicial bodies (Labor
Arbiter & NLRC), which have acquired expertise because their jurisdiction is
confined to specific matters, are accorded great respect and even finality.
These findings are binding upon the Court, unless there has been a grave
abuse of discretion or where it is clearly shown that they were arrived at
arbitrarily or in utter disregard of evidence on record.
2.) No. Under No. 6, Section c, Part II of the POEA “Standard Employment
Contract Governing the Employment of All Filipino Seamen On-Board
Ocean-Going Vessels, it is provided: “No compensation shall be payable in
respect of any injury, incapacity, disability or death resulting from a wilful
act on his own life by the seaman, provided, however that the employer can
prove that such injury, incapacity, disability, or death is directly
attributable to him.”
Petition is granted. The decision of the CA is reversed and set aside.
Decision of the Labor Arbiter hereby reinstated and affirmed.