In a claim for death benefits, the burden of proving that a seafarer’s death was work-related lies with the claimant, not the employer. The Supreme Court clarified that the claimant must present substantial evidence to establish the connection between the seafarer’s work and their cause of death to receive full benefits under the POEA-SEC (Philippine Overseas Employment Administration Standard Employment Contract). If work-relatedness is not proven, benefits may still be available under a Collective Bargaining Agreement (CBA), albeit at a reduced amount, depending on the agreement’s terms.

Sailing the Seas of Contracts: Whose Burden is it to Prove the Cause of Death?

Efren B. Malicse, an able-bodied seaman, passed away while working on board Maersk Tide. His widow, Rosemary G. Malicse, sought death benefits, arguing that her husband’s death was covered under the ITF (International Transport Workers’ Federation) Agreement, which provides benefits regardless of the cause of death. The company offered a partial settlement based on the CBA but denied full benefits, claiming the death was not work-related. The legal question before the Supreme Court was: Who bears the burden of proving whether the seafarer’s death was work-related, and which contract—POEA-SEC, CBA, or ITF Agreement—applies?

The Supreme Court first addressed the applicability of the ITF Agreement. The Court emphasized that before a claimant can avail of the benefits under the ITF Agreement, specific conditions must be met. These conditions include proof that the seafarer was a member of a union affiliated with the ITF and that the company had a special agreement with the union or the ITF. The Court found that the lower courts had failed to establish these conditions with concrete evidence. Because the respondent failed to prove these conditions, the court ruled that the ITF Agreement could not be the basis for awarding death benefits.

Given the inapplicability of the ITF Agreement, the Court turned to the POEA-SEC and the CBA. The Court reiterated the principle that CBA clauses that are more beneficial to the seafarer prevail over the POEA-SEC. Section 20(A)(1) of the POEA-SEC stipulates a death benefit of US$50,000 for work-related deaths, while the CBA provided US$80,000 for deaths due to accidents and US$40,000 for deaths from natural causes or illness. However, to claim the higher benefit under the POEA-SEC, the claimant must first establish that the death was work-related.

Building on this principle, the Court addressed the critical issue of the burden of proof. The Court unequivocally stated that the burden of proving entitlement to benefits lies with the claimant, not the employer. This means Rosemary had to provide substantial evidence demonstrating that Efren’s death was work-related. The Court cited previous rulings to support this position, emphasizing that claimants cannot simply rely on the disputable presumption of work-relatedness but must actively substantiate their claims.

The Court highlighted that the CA erred by placing the burden on the employer to prove that the seafarer’s death was not work-related. Instead, the correct approach is to assess whether the claimant has proven the requisites for compensability under Section 32-A of the POEA-SEC. These requisites include demonstrating that the seafarer’s work involved specific risks, the disease was contracted as a result of exposure to those risks, the disease was contracted within a specific period of exposure, and there was no negligence on the part of the seafarer.

Applying these principles to the case, the Court found that Rosemary failed to provide sufficient evidence to establish the work-relatedness of Efren’s death. She did not describe the specific tasks Efren performed on board the vessel or explain how his work environment contributed to his illness. The Court emphasized that general statements without supporting documents or medical records are insufficient to prove a causal link between the seafarer’s work and their death. Because of the respondent’s failure to prove work-relatedness, the higher death benefit under the POEA-SEC was not applicable.

Despite the lack of proof of work-relatedness, the Court acknowledged that Rosemary was still entitled to benefits under the CBA. Section 25(5) of the CBA provided a death benefit of US$40,000 regardless of the cause of death, as long as the seafarer died while employed by the company. Since Efren died during his employment, Rosemary was entitled to this amount. The Court noted that the company had already offered this amount in good faith, negating any basis for imposing moral or exemplary damages, or attorney’s fees.

In conclusion, the Supreme Court clarified the burden of proof in seafarer death benefit claims and emphasized the importance of providing substantial evidence to establish work-relatedness. While the ITF Agreement was deemed inapplicable due to lack of evidence, the CBA provided a safety net for the claimant. The Court reversed the CA’s decision and ordered the company to pay the US$40,000 benefit under the CBA, without additional damages or fees.

FAQs

What was the key issue in this case?	The central issue was determining who bears the burden of proving whether a seafarer’s death is work-related for the purpose of claiming death benefits, and which contract governs the benefits.
What is the POEA-SEC?	The POEA-SEC is the Philippine Overseas Employment Administration Standard Employment Contract, which sets the minimum terms and conditions of employment for Filipino seafarers.
What is a Collective Bargaining Agreement (CBA)?	A CBA is a negotiated agreement between an employer and a labor union representing the employees, which can provide more beneficial terms than the POEA-SEC.
Who has the burden of proof in claiming death benefits?	The claimant (e.g., the seafarer’s beneficiary) has the burden of proving that the seafarer’s death was work-related to claim the higher benefits under POEA-SEC.
What evidence is needed to prove work-relatedness?	Substantial evidence is required, including a description of the seafarer’s tasks, how the work environment caused the illness, and medical records linking the illness to the work.
What happens if work-relatedness is not proven?	If work-relatedness is not proven, the beneficiary may still be entitled to benefits under the CBA, depending on its terms, even if the death was not work-related.
What did the Court rule regarding the ITF Agreement in this case?	The Court ruled that the ITF Agreement was not applicable because the claimant failed to prove that the seafarer’s union was affiliated with the ITF and that there was a special agreement with the company.
What death benefit was awarded in this case?	The Court awarded the death benefit of US$40,000 provided under the Collective Bargaining Agreement (CBA) because the claimant did not prove that the seafarer’s death was work-related.
Why were moral and exemplary damages not awarded?	Moral and exemplary damages were not awarded because the company had acted in good faith by offering the US$40,000 benefit under the CBA, negating any indication of bad faith or malice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Maersk-Filipinas Crewing, Inc. vs. Rosemary G. Malicse, G.R. Nos. 200576 & 200626, November 20, 2017