4/10/2020
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I
WHETHER A SPECIAL CIVIL ACTION OF CERTIORARI INCLUDES
CORRECTION OF THE NLRC'S EVALUATION OF THE EVIDENCE AND FACTUAL
FINDINGS BASED THEREON OR CORRECTION OF ERRORS OF FACTS IN THE
JUDGMENT OF THE NLRC;
II
WHETHER THE NEGLIGENT ACTS OF SUPPOSEDLY FAILING TO TAKE SUCH
MEASURES FOR THE COMFORT AND SAFETY OF THE DECEASED SEAFARER,
AMONG OTHERS, WHICH WERE ESPECIALLY EMPHASIZED IN THE ASSAILED
CA DECISION AND WHICH ACTUALLY REFERRED TO ACTS COMMITTED BY
THE SHIPMATES OF THE DECEASED, BUT POSITIVELY ATTRIBUTED TO
PETITIONERS AND FOR WHICH THE LATTER ARE NOW BEING HELD LIABLE
– ARE IN THE NATURE OF AN ENTIRELY DIFFERENT SOURCE OF
OBLIGATION THAT IS PREDICATED ON QUASI-DELICT OR TORT AS
PROVIDED UNDER OUR CIVIL LAWS AND, THUS, HAS NO REFERENCE TO
OUR LABOR CODE;
III
WHETHER THE DEATH OF SEAFARER IN THIS CASE WAS A RESULT OF A
DELIBERATE/WILLFUL ACT ON HIS OWN LIFE, AN ACT DIRECTLY
ATTRIBUTABLE TO THE DECEASED, AND NO OTHER, AS FOUND AND SO
RULED BY THE LABOR ARBITER AND NLRC, AS TO RENDER HIS DEATH NOT
COMPENSABLE.
Petitioner claimed that Jacinto's death is not compensable, considering that the latter's
death resulted from his willful act. It argued that the rule that the employer becomes
liable once it is established that the seaman died during the effectivity of his
employment contract is not absolute. The employer may be exempt from liability if he
can successfully prove that the seaman's death was caused by an injury directly
attributable to his deliberate or willful act, as in this case.
We find merit in the petition.
In a petition for review on certiorari, our jurisdiction is limited to reviewing errors of law
in the absence of any showing that the factual findings complained of are devoid of
support in the records or are glaringly erroneous. We are not a trier of facts, and this
applies with greater force in labor cases. Findings of fact of administrative agencies
and quasi-judicial bodies, which have acquired expertise because their jurisdiction is
confined to specific matters, are generally accorded not only great respect but even
finality. They are binding upon this Court unless there is a showing of grave abuse of
discretion or where it is clearly shown that they were arrived at arbitrarily or in utter
disregard of the evidence on record. This case is no different.
As found by the Labor Arbiter, Jacinto's jumping into the sea was not an accident but
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