Facts:
This case concerns the death of Second Engineer Napoleon B. Abordo, employed by Norse Management Co. (PTE), while onboard the Singaporean-registered vessel, M.T. “Cherry Earl.” Abordo died from an apoplectic stroke during his employment, earning a monthly salary of US$850. His widow, Restituta C. Abordo, sought death compensation benefits, accrued leave pay, funeral expenses, attorney’s fees, and other reliefs, arguing that compensation should be based on the law where the vessel is registered (Singapore law). On the contrary, Norse Management offered P30,000.00 as death benefits, based on the National Seamen Board’s (NSB) Memorandum Circular No. 25, contending that the NSB could not apply Singapore law due to lack of judicial notice.
The case proceeded through the NSB, where Hearing Officer III, Rebene C. Carrera, ruled in favor of Abordo, ordering Norse Management to pay sums equating to 36 months of the deceased’s salary, funeral expenses, and attorney’s fees. Norse Management appealed to the Ministry of Labor, which reiterated the NSB’s decision after reviewing the case, holding that administrative and quasi-judicial bodies like the NSB are not bound by the usual procedural technicalities concerning the evidence of foreign laws.
Issues:
1. Whether Singapore law should apply in determining the compensation benefits owing to the widow of the deceased.
2. Whether administrative and quasi-judicial bodies like the NSB should strictly adhere to procedural rules of evidence in the application of foreign laws.
Court’s Decision:
The Supreme Court denied the petition, affirming the decisions of the NSB and Ministry of Labor. It based its decision on the rationale that in administrative proceedings, the strict rules of evidence do not apply, and therefore, the National Seamen Board did not err in applying Singapore law. The Court referenced the employment agreement between Norse Management and Abordo, which stated that compensation would be based on either the Workmen’s Compensation Act of the Philippines or the Workmen’s Insurance Law of the vessel’s registry, whichever is greater. The decision was also supported by precedent and the explicit jurisdiction granted to the NSB over matters involving Filipino seamen for overseas employment.
Doctrine:
The case reiterates the doctrine that in administrative and quasi-judicial proceedings, the technical rules of evidence applied in judicial trials do not strictly apply. It also establishes that in cases involving the employment of Filipino seamen onboard foreign vessels, the laws of the country where the vessel is registered should be considered if they provide greater benefits than Philippine law, in accordance with the employment agreement’s stipulations.
Class Notes:
1. Jurisdiction of the National Seamen Board – The NSB has original and exclusive jurisdiction over all matters involving employer-employee relations concerning Filipino seamen for overseas employment, as provided under Article 20 of the Labor Code of the Philippines.
2. Application of Foreign Laws in Administrative Proceedings – Foreign laws must be alleged and proved like any other fact, but administrative and quasi-judicial bodies are not bound strictly by this requirement, in favor of expediting the resolution of cases and serving justice.
3. Role of Employment Contracts – The specifics of an employment contract, especially clauses that refer to applicable laws for dispute resolution, are pivotal in determining the jurisdiction and applicable laws in cases of disputes arising from such contracts.
4. Favoring Labor – Consistent with Article IV of the Labor Code, in cases of ambiguity or doubt, provisions are resolved in favor of labor.
Historical Background:
The case reflects the evolving legal landscape and administrative practices concerning the employment of Filipino seamen on foreign vessels, addressing the complexity of applying foreign laws and agreements in Philippine legal and administrative proceedings. It underscores the special considerations and legal principles developed to navigate the intersection of international maritime employment and national labor laws, with a view towards protecting the welfare of Filipino seamen employed across global jurisdictions.
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