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c. The employer shall pay the beneficiaries of the seafarer the
[Philippine] currency equivalent to the amount of One Thousand
US dollars (US$1,000) for burial expenses at the exchange rate
prevailing during the time of payment.
Akin to the death benefits under the Labor Code, these benefits under the POEA-SEC
are given when the employee dies due to a work-related cause during the term of his
contract.[48] The liability of the shipowner or agent under the POEA-SEC has likewise
nothing to do with the provisions of the Code of Commerce regarding maritime
commerce. The death benefits granted under the POEA-SEC is not due to the death of a
passenger by or through the misconduct of the captain or master of the ship; nor is it
the liability for the loss of the ship as result of collision; nor the liability for wages of the
crew. It is a liability created by contract between the seafarers and their employers, but
secured through the State's intervention as a matter of constitutional and statutory
duty to protect Filipino overseas workers and to secure for them the best terms and
conditions possible, in order to compensate the seafarers' heirs and dependents in the
event of death while engaged in the performance of their work or employment. The
POEA-SEC prescribes the set of standard provisions established and implemented by
the POEA containing the minimum requirements prescribed by the government for the
employment of Filipino seafarers. While it is contractual in nature, the POEA-SEC is
designed primarily for the protection and benefit of Filipino seamen in the pursuit of
their employment on board ocean-going vessels.[49] As such, it is deemed incorporated
in every Filipino seafarers' contract of employment.[50] It is established pursuant to
POEA's power "to secure the best terms and conditions of employment of Filipino
contract workers and ensure compliance therewith" and "to protect the well-being of
Filipino workers overseas"[51] pursuant to Article 17 of the Labor Code as amended by
Executive Order (EO) Nos. 797[52] and 247.[53]
But while the nature of death benefits under the Labor Code and the POEA-SEC are
similar, the death benefits under the POEA-SEC are intended to be separate and distinct
from, and in addition to, whatever benefits the seafarer is entitled to under Philippine
laws, including those benefits which may be claimed from the State Insurance Fund.[54]
Thus, the claim for death benefits under the POEA-SEC is the same species as the
workmen's compensation claims under the Labor Code - both of which belong to a
different realm from that of Maritime Law. Therefore, the limited liability rule does not
apply to petitioner's liability under the POEA-SEC.
Nevertheless, the Release and Quitclaim benefit petitioner as a solidary debtor.
All the same, the Release and Quitclaim executed between TEMMPC, TMCL and Capt.
Oscar Orbeta, and respondents redounded to the benefit of petitioner as a solidary
debtor.
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/62118
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