Agile Maritime vs.

Siador

FACTS
 Dennis Siador, son of Respondent Apolinario Siador, was contracted as a seafarer by
Petitioner Agile Maritime.
 During his employment, Dennis jumped overboard and was lost at sea.
 Respondent filed a complaint for death benefits.
 Petitioner denied Respondent’s claim, contending that under the agreement, the Petitioner
would not be liable for death benefits if death was caused by the wilful or wrongful acts
of the employee.
 Respondent claimed that the death was not wilful as the deceased had been mentally
unstable at the time of death. To support this, Respondent cited the personal accounts of
the Filipino crewmembers who claimed that the deceased had been behaving unusually
days before the incident and that he appeared very disturbed, anxious, depressed, and
restless (Crewmembers’ Statement).
 Counter to this, Petitioner pointed out that in the same Crewmembers’ Statement, the
crewmembers in contacts with the deceased narrated that on the day of the incident, the
deceased was “depressed but not ill and just wanted to be alone.” Petitioner further
pointed out that the crewmember who threw a life ring to the deceased stated that the
deceased did not swim towards the life ring but merely floated on his back.
 The LA and the NLRC both dismissed Respondent’s claims.
 The CA thereafter partially reversed the ruling, granting $60k in death benefits but did
not grant damages. The CA held that Dennis’ wilfulness could not be presumed.
Petitioner now appeals to the SC.

ISSUE
Whether Petitioner is liable to pay death benefits? - NO

HELD
It must be noted that at the start, the burden of proof was on Respondent to prove the death of his
son was work-related or happened during employment. Having discharged this burden, the same
was shifted to Petitioner who could then disprove liability by proving that the death attributable
to the wilful or wrongful act of the employee. The burden of proof can be discharged by either
party through substantial evidence.

The Petitioner was successful in proving that the death was wilful in this case. As a consequence,
the burden shifts again to the heir of the deceased. However, they were not able to prove that the
deceased’s acts were not wilful. While Respondent claims that the deceased was not mentally
stable, the facts and the legal presumption of sanity lead the SC to conclude that the LA and the
NLRC were correct in ruling that the acts were wilful and warranted the dismissal of the
complaint.

The CA was incorrect in ruling that the wilfulness of the deceased could not be presumed. This
effectively shift the burden to the Petitioner when it should have been the Respondent who had
the burden of proving the lack of wilfulness of the deceased. Respondent’s complaint must be
dismissed because of insufficiency of his evidence to support his claim.