Seafarer Death Benefits: Claims Must Be Timely and Proven Work-Related

G.R. No. 255802, October 12, 2022

Imagine a Filipino seafarer, working tirelessly on the high seas to provide for his family. What happens when tragedy strikes, and he passes away? His family expects to receive death benefits, but what if their claim is denied due to legal technicalities? This is the harsh reality highlighted in the Supreme Court case of One Shipping Corporation v. Heirs of Ricardo R. Abarrientos. This case underscores the importance of understanding the strict rules surrounding prescription periods and proving the work-relatedness of a seafarer’s death to successfully claim death benefits.

Understanding Seafarer Death Benefit Claims in the Philippines

The Philippines, being a major supplier of maritime labor, has established laws and regulations to protect its seafarers. These protections include death benefits for the seafarer’s family in case of death during employment. However, claiming these benefits is not always straightforward. Two key hurdles often arise: prescription (the time limit to file a claim) and compensability (proving the death was work-related). This case serves as a stark reminder that even valid claims can be lost if not pursued within the prescribed timeframe and with sufficient evidence.

The Legal Framework for Seafarer Benefits

Several legal instruments govern seafarer employment and benefits in the Philippines. These include:

• The Labor Code of the Philippines: Article 291 sets a three-year prescriptive period for money claims arising from employer-employee relations.
• The POEA Standard Employment Contract (POEA-SEC): This contract, deemed integrated into every seafarer’s employment agreement, outlines the minimum acceptable terms and conditions, including death benefits. Section 30 reiterates the three-year prescriptive period.
• Collective Bargaining Agreements (CBAs): These agreements between unions and shipping companies may provide for benefits exceeding the minimum standards in the POEA-SEC.

The POEA-SEC is particularly crucial. It states in Section 30: “All claims arising from this contract shall be made within three (3) years from the date the cause of action arises, otherwise the same shall be barred.” This means the clock starts ticking from the moment the right to claim benefits arises.

The interplay between these laws is critical. The Labor Code sets the general rule for prescription, while the POEA-SEC and CBAs define the specific circumstances under which death benefits are payable.

The Case of One Shipping Corporation vs. Heirs of Abarrientos

Ricardo Abarrientos, a Chief Officer for One Shipping Corporation, was repatriated on February 20, 2014, before the end of his nine-month contract. He received his final salary and benefits, executing a quitclaim on April 14, 2014. Six months later, on August 19, 2014, he was hospitalized and diagnosed with pancreatic cancer, which metastasized. He died on September 3, 2014, due to liver cirrhosis.

His heirs filed a claim for death benefits under the CBA on March 2, 2018 – almost four years after his repatriation and death. They argued that his death was work-related due to the harsh conditions and stress he endured at sea.

The Panel of Voluntary Arbitrators initially granted the claim, but the Supreme Court ultimately reversed this decision, citing two main reasons:

• Prescription: The claim was filed beyond the three-year prescriptive period.
• Lack of Proof of Compensability: The heirs failed to prove that Ricardo’s death was work-related.

The Court emphasized the importance of filing claims promptly. It stated, “The law aids the vigilant, not those who slumber on their rights.”

Furthermore, the Court found that the heirs did not present sufficient evidence to link Ricardo’s illness to his work environment. The Court emphasized the need for substantial evidence, stating that conclusions must be based on “real evidence and not just inferences and speculations.” Specifically, the Court noted the lack of medical evidence connecting his duties as Chief Officer to the risk factors of pancreatic cancer or liver cirrhosis.

As the Supreme Court further stated:

“It is a basic rule in evidence that the party who made an affirmative allegation carries the burden to prove it. Since mere allegation is not equivalent to evidence, respondents’ allegation that they made timely claims from petitioner are self-serving and devoid of any evidentiary weight.”

Despite denying the death benefits, the Supreme Court, in a display of social justice, awarded the heirs financial assistance of P100,000, recognizing Ricardo’s long service with the company.

Practical Implications for Seafarers and Their Families

This case offers critical lessons for seafarers and their families:

• Act Promptly: File claims for death benefits as soon as possible after the seafarer’s death. Do not delay, as the three-year prescriptive period is strictly enforced.
• Gather Evidence: Collect all relevant documents, including medical records, employment contracts, and any evidence of the seafarer’s working conditions.
• Establish Work-Relatedness: Obtain medical opinions linking the seafarer’s illness to their work environment.

Key Lessons

• Time is of the Essence: The three-year prescriptive period is a strict deadline.
• Proof is Paramount: Mere allegations are not enough; substantial evidence is required.
• Seek Expert Advice: Consult with a maritime lawyer to understand your rights and navigate the claims process.

Hypothetical Example: A seafarer dies two years after repatriation from a heart attack. His family believes his stressful work environment contributed to his condition. They should immediately consult with a lawyer, gather his medical records, and obtain a medical opinion linking his heart condition to his work stressors to ensure a timely and well-supported claim.

Frequently Asked Questions (FAQs)

Q: What is the prescriptive period for filing a seafarer death benefit claim?

A: Three years from the date the cause of action arises, which is generally the date of the seafarer’s death.

Q: What happens if I file my claim after the prescriptive period?

A: Your claim will likely be denied, as it will be considered barred by prescription.

Q: What evidence do I need to prove that a seafarer’s death was work-related?

A: Medical records, employment contracts, witness testimonies, and medical opinions linking the illness to the seafarer’s work environment.

Q: What if the seafarer died after the contract ended?

A: You may still be able to claim benefits if you can prove that the death was caused by a work-related illness or injury sustained during the term of the contract.

Q: Can I still get financial assistance even if my death benefit claim is denied?

A: Possibly. The Supreme Court has, in some cases, granted financial assistance based on humanitarian considerations, such as the seafarer’s length of service.

Q: What is the role of the POEA-SEC in seafarer death benefit claims?

A: The POEA-SEC sets the minimum standards for seafarer employment, including death benefits, and is deemed integrated into every seafarer’s employment contract.

Q: What if the CBA provides more benefits than the POEA-SEC?

A: The CBA will generally prevail, as it provides for more favorable terms and conditions for the seafarer.

ASG Law specializes in maritime law and seafarer claims. Contact us or email hello@asglawpartners.com to schedule a consultation.