INC Shipmanagement, Inc. v.

Moradas

Petitioners: INC Shipmanagement, Inc., Capt. Sigfredo Monterroyo and/or Interorient

Respondents: Alexander Moradas

Doctrines:
(1) In labor cases, as in other administrative proceedings, only substantial evidence or such
relevant evidence as a reasonable mind might accept as sufficient to support a conclusion is
required. To note, considering that substantial evidence is an evidentiary threshold, the Court, on
exceptional cases, may assess the factual determinations made by the NLRC in a particular case.
(2) SC does not reexamine conflicting evidence, reevaluate the credibility of witnesses, or
substitute the findings of fact of the NLRC, an administrative body that has expertise in its
specialized field. Nor do we substitute our “own judgment for that of the tribunal in determining
where the weight of evidence lies or what evidence is credible.” The factual findings of the
NLRC, when affirmed by the CA, are generally conclusive on this Court.

Nevertheless, there are exceptional cases where SC, in the exercise of its discretionary appellate
jurisdiction may be urged to look into factual issues raised in a Rule 45 petition. For instance,
when the petitioner persuasively alleges that there is insufficient or insubstantial evidence on
record to support the factual findings of the tribunal or court a quo, as Section 5, Rule 133 of the
Rules of Court states in express terms that in cases filed before administrative or quasi-judicial
bodies, a fact may be deemed established only if supported by substantial evidence.

1. Moradas was employed as a wiper for MV Commander by INC Shipmanagement for its
principal, Interorient Navigation, for 10 months with salary of $360/mo. plus benefits
2. He claimed that while he was disposing of the garbage in the incinerator room, chemicals
splashed all over his body because of an explosion
3. He was sent to the Prince of Wales hospital where he was found to have suffered deep
burns. Upon his request, he was sent home. Moradas was admitted to St. Luke’s Medical
Center
4. He underwent debridement and was referred to a physical therapist for hydrotherapy.
Physician reported that he would fully heal in a period of 3 to 4 months
5. Claiming that the burns rendered him permanently incapable of working again as a
seaman, respondent demanded for the payment of his full disability benefits under
Section 20 (B) in relation to Sections 30 and 30-A of the Philippine Overseas
Employment Agency (POEA) Standard Employment Contract (POEA-SEC), in the
amount of US$60,000.00, which petitioners refused to heed.
6. INC Shipmanagement refused this claim.
 7. Moradas filed a complaint for the same, plus moral and exemplary damages
8. According to INC, his injury was self-inflicted, hence, not compensable under Sec 20
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(D) . They denied that the vessel’s incinerator exploded and claimed that respondent
burned himself by pouring paint thinner on his overalls and thereafter set himself on fire.
He did this since he was to be dismissed after stealing some supplies
9. Moradas denied burning himself and for causing the flooding, and posited that the
affidavits of the crew members have no probative value, being mere hearsay and self-
serving

RULINGS OF LOWER COURTS:

1. LA: in favor of INC. Moradas’ injury was self-inflicted, there was no explosion.
2. NLRC (MR DENIED): sustained LA. While some of the affidavits were not notarized,
corroborating testimonial must be taken as a whole. Moradas not motivated by ill will.
3. CA: NLRC grave abuse of discretion. No logical and causal connection between the
pilferage and the conclusion that the injury was self-inflicted. Contrary to human nature.
P’s failed to discharge the burden of proving that R’s injury was directly attributable to
him, as required under Sec 20 (D) of the POEA-SEC. P pay $60,000.

ISSUES:

1. WoN the CA erred in finding that the NLRC gravely abused its discretion when it
denied respondent’s claim for disability benefits – YES

The Court holds that the CA erred in attributing grave abuse of discretion on the part of the
NLRC in affirming the LA’s dismissal of respondent’s complaint.

Moradas executed his employment contract on July 17, 2000, incorporating terms and
conditions of the 2000 POEA-SEC3. HOWEVER, implementation of 2000 POEA-SEC was
temporarily suspended by the Court on Sept. 11, 2000, particularly Sec 20 (A), (B), and (D).
Suspension was lifted only on June 5, 2002. HENCE, the determination of his entitlement to
disability benefits should be resolved under 1996 POEA-SEC.

• Sec 20 (B) provides that the employer shall be liable for the injury or illness suffered by a
seafarer during the term of his contract. No need to show that it was work- related, only that it
was contracted during the term of the contract.
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• Sec 20 (D) provides for when the employer may be exempt from liability.

• The onus probandi falls on INC to establish and substantiate their claim that Moradas injury
was by his willful act.

NLRC has cogent bases to conclude that INC successfully discharged the burden of
proving by substantial evidence that R’s injury was directly attributable to himself.

• Records bear out circumstances which lead to the reasonable conclusion that Moradas was
responsible for the flooding and burning incidents.

LA and NLRC gave credence to the corroborating testimonies that R was seen alone
in the vicinity of the portside seachest and the boiler deck right before the
flooding

Moradas neither denied nor provided an explanation, especially as to why all the
engine room staff, except for him, responded to the alarm during the flooding

He also failed to controvert claims that he went into the paint room and soaked himself
in thinner and set himself ablaze

• Moradas’ version that the burning was caused by an accident is hardly supported by evidence.
He claimed that the affidavits of the crew members were self-serving and hearsay, but he
was not able to substantiate his own theory.

• INC’s theory that the burns were self-inflicted gains credence through the existence of motive.

• LA and NLRC found that prior to the burning incident, he was caught pilfering the vessel’s
supplies and was told that he would be dismissed. This supports the conclusion that R
may have harbored a grudge against the captain and chief steward who denied giving him
the supplies.

• SC: no need to look into R’s mental unfitness. Totality of the above-stated circumstances show
that the burning was not a product of impaired mental disposition, but an incident which sprung
from his own volition.

2. WoN Petitioners were able to substantiate that Respondent’s injury was self-inflicted,
hence, notcompensable - YES
• INC established through substantial evidence that Moradas’ injury was self-inflicted and
therefore, not compensable.

Petition GRANTED. CA REVERSED and SET ASIDE.

Brion, J., Concurring and Dissenting:

I. Concurs with ponencia that Moradas’ complaint for total and permanent disability
benefits should be dismissed.
a. He should only be entitled to temporary total disability in light of his disability
for an extended period of 169 days.II. Disagrees with the ponencia which stated
that the NLRC had cogent legal bases to conclude that INC has proven by
substantial evidence Moradas’ injuries were self-inflicted. Basic rule in evidence
is that each party must prove his affirmative allegation still applies.
b. Substantial evidence is such relevant evidence as a reasonable mind might
accept as adequate to support a conclusion, even if other minds equally reasonable
might conceivably opine otherwise.
c. t was incumbent upon Moradas to prove that:
i. His injury was suffered during the term of employment
ii. Seafarer report to the company physician for a post-employment
medical examination and evaluation within 3 working days from the
time of his return
iii. Any disability should be assessed by the company physician on the
basis of the Schedule of Disability Grades under the POEA-SEC
d. Moradas is NOT required to prove that his injury was not due to his own willful
act. This burden falls on INC as part of their defense, after invoking Sec 20 (D).
e. The rule that factual findings of the LA and NLRC are binding on the courts
apply only if these are supported by substantial evidence.
f. CA’s findings that there was (1) no logical and causal connection between the
pilferage and flood, (2) human nature and common experience dictate that no
person in the right mind would willfully burn himself, and (3) location of the
burns inconsistent with self-inflicted injury, raised doubts as to Moradas’
complicity in the flooding of the engine room.
g. The conclusion of the LA and NLRC by itself was not an adequate conclusion of
a reasonable mind.
h. Ponencia made a conclusive factual finding that R was caught pilfering when the
 latter specifically denied such accusation.
i. Moradas also specifically denied the claim that he was seen going into the paint
room.
j. Other crew members who executed affidavits have no personal knowledge about
the burning itself.
k. Moradas’ mental disposition would have established the substantial evidence
requirement lacking in this case.
II. Votes to partially grant. Modify to reflect that R is entitled to temporary total
disability.