Shipmanagement Inc., et al. v Alexander Moradas GR NO. 178564, January 15, 2014

Injuries due to the willful act of the employee is not compensable

FACTS:

The respondent was employed as a wiper for the vessel M/V Commander of the Shipmanagement Inc. The respondent claims that chemicals were splashed all over his body during garbage disposal in the vessel's incinerator room due to an explosion. He was repatriated and admitted to St. Luke's Medical Center. He was diagnosed with thermal burns. He now claims for the payment of his full disability benefit under Section 20 (B) in relation to Section 30 and 30-A of the POEA-SEC contending that his burns render him permanently disabled to work as a seaman. On the other hand, the petitioner disputed the claim of the respondent that he is entitled to the disability benefit. It contends that the burns and injury of the respondent are self inflicted by pouring himself with a paint thinner and set himself on fire. This was after he was dismissed after being caught stealing the supplies from the vessel. Report of the ship captain as well as affidavits of the crew members were submitted.

The Labor Arbiter and NLRC ruled in favor of the respondent, but the CA reversed the judgment, hence this petition for review on certiorari to the Supreme Court. 

ISSUE:

Whether or not the respondent is entitled to the disability benefit.

RULING:

No. He is not entitled.

The court held to be entitled for the disability benefit it is not necessary to show that the injury was work-related. It must only be proven to have been contracted during the term of the contract. This rule is not absolute, however, and among the grounds for the exemption from liability by the employer is when the injury or cause of the disability is due to the willful and deliberate act of the seaman. The court found some grounds to conclude that the respondent's injury is indeed deliberate and self inflicted because there is no showing of evidence on record that the burning was due to an accident and that the petitioner's theory that the respondent's burn were self inflicted is correct as supported by evidence that shows the respondent's motive.