Interorient Maritime Enterprises, INC vs NLRC : 115497 : September ... http://sc.judiciary.gov.ph/jurisprudence/1996/sept1996/115497.htm no factual and legal bases is belied by the adoption with approval by the public respondent of the findings of the POEA Administrator, which recites at length the reasons for holding that the deceased Pineda was mentally sick prior to his death and concomitantly, was no longer in full control of his mental faculties. First, a word about the evidence supporting the findings of the POEA Administrator. We have held that claims of overseas workers against their foreign employers should not be subjected to the rules of evidence and procedure that courts usually apply to other complainants [12] who have more facility in obtaining the required evidence to prove their demands. Section 5, Rule 133 of the Rules of Court provides that in cases filed before administrative or quasi-judicial bodies (like the POEA), a fact may be deemed established if it is supported by substantial evidence, i.e., that amount of evidence which a reasonable mind might accept as adequate to [13] justify a conclusion. In this instance, seaman Pineda, who was discharged in Dubai, a foreign land, could not reasonably be expected to immediately resort to and avail of psychiatric examination, assuming that he was still capable of submitting himself to such examination at that time, not to mention the fact that when he disembarked in Dubai, he was already discharged and without employment -- his contract having already run its full term -- and he had already been put on a plane bound for the Philippines. This explains the lack or absence of direct evidence showing his mental state. The circumstances prior to and surrounding his death, however, provide substantial evidence of the existence of such mental defect or disorder. Such mental disorder became evident when he failed to join his connecting flight to Hongkong, having during said stopover wandered out of the Bangkok airports immigration area on his own. We can perceive no sane and sufficient reason for a Pinoy overseas contract worker or seaman to want to while away his time in a foreign land, when he is presumably unfamiliar with its native tongue, with nothing to do and no source of income, and after having been absent from kith and kin, hearth and home for almost an entire year. Nor can we find any plausible reason for him to be wielding a knife and scaring away passersby, and even taking a stab at an armed policeman, unless he is no longer in full possession of his sanity. To our mind, these circumstances are sufficient in themselves to produce a firm conviction that the deceased seaman in this case was no longer in full control of his senses when he left his work. To reiterate, in this case, no more than substantial evidence is required. Second Issue: Employer Exempted from Liability? It is petitioners contention that Pinedas death caused by his own willful act of attacking a Thai policeman and getting shot at in self-defense is not compensable, inasmuch as Par. 6, Section C, Part II of the POEAs Standard Format Contract of Employment for Seamen states that: No compensation shall be payable in respect of any injury, incapacity, disability or death resulting from a (deliberate or) willful act on his own life by the seaman(,) provided, however, that the employer can prove that such injury, incapacity, disability or death is directly attributable to the seaman. (underscoring supplied). Moreover, petitioners contend that this Court already held in the case of Mabuhay Shipping [14] Services, Inc. vs. NLRC and Cecilia Sentina that the employer is not liable for the willful act of an employee on his own life. Further, Article 172 of the Labor Code provides for a limitation on the liability of the State Insurance Fund when the disability or death was occasioned by the employees intoxication, willful intention to injure or kill himself or another, notorious negligence x x x. 4 of 7 1/20/2016 12:35 PM