Labor Law Digest: MARITIME FACTORS INC. V. BIENVENIDO HINDANG [G.R. No. 151993, October 19, 2011]

Topic: Exception to the rule on availing death benefits

MARITIME FACTORS INC. V. BIENVENIDO HINDANG

[G.R. No. 151993, October 19, 2011]

Facts:

Petitioner is a domestic manning agency for sea vessel engaged the services of Danilo to work as GP/Deckhand effective for 12 months contract. However, while on board the vessel somewhere in Saudi Arabia, his body was found inside the locker of his cabin. Upon autopsy immediately after the death, the medical examiner of the Saudi police concluded that Danilo committed suicide by hanging himself. The body was repatriated to the Philippines.

Thereafter, Danilo’s brother filed for death compensation benefits against petitioner. Petitioner denied, contending they are not liable since the cause of Danilo’s death was suicide, hence, not compensable.

Labor Arbiter decided in favour of Danilo’s heirs. NLRC affirmed, CA sustained.

ISSUE:

If the employer is exempt from paying death compensation, when the employee has committed suicide.

RULING:

Yes. By way of an exception, the employer may be exempt from liability to the employee's heirs for death compensation benefits, if the employer can successfully prove that the seaman's death was caused by an injury directly attributable to his deliberate or willful act. In this case, Maritime Factors was able to prove that Danilo's death was attributable to his deliberate act of killing himself by committing suicide. Thus, the company does not need to pay for any death benefits to the employee’s heirs.

           

General rule - The death of a seaman during the term of employment makes the employer liable to his heirs for death compensation benefits.