TITLE: Crewlink v.Teringtering, G.R. No.

166803, October 14, 2012

CREWLINK, INC. and/or GULF MARINE SERVICES (petitioners) v EDITHA TERINGTERING, for
her behalf and in behalf of minor EIMAEREACH ROSE DE GARCIA TERINGTERING (respondents).
Ponente: Justice Peralta
Topics: Restriction on Civil Capacity- Restriction on Capacity to Act- Insanity
Doctrines and Provisions:
Article 38 of the Civil Code
Article 12 (1) of the Revised Penal Code
No. 6, Section C, Part II of the POEA "Standard Employment Contract Governing the Employment of All
Filipino Seamen On-Board Ocean-Going Vessels"
Doctrine: The issue of Insanity is a question of fact; establishing the insanity of an accused requires
opinion testimony which may be given by a witness who is intimately acquainted with the person claimed
to be insane, or who has rational basis to conclude that a person was insane based on the witness own
perception of the person, or who is qualified as an expert, such as a psychiatrist

Facts:

April 9, 2011, Jacinto Teringtering jumped overboard at about 8:20pm but was recovered.
Jacinto jumped overboard again at about 10:30pm, his body was revived at 11:00pm
April 18, 2001, a death certificate was issued by the Ministry of Health of the United Arab
Emirates wherein it was stated that Jacinto died on April 9, 2001 due to asphyxia of drowning.
Editha Teringtering claimed payment for death compensation; Crewlink refused because Jacinto
Teringtering committed suicide.
February 12, 2002- the Labor Arbiter dismissed the case for lack of merit because his death was
directly attributable to him
February 20, 2003- Teringtering appealed before the NLRC which affirmed in toto the ruling of
the Labor Arbiter.
Teringtering filed a petition for certiorari under Rule 65 before the Court of Appeals and sought
the nullification of the National Labor Relations Commission (NLRC) Resolution.
July 8, 2004- The CA reversed and set aside the assailed Resolution of the NLRC.
Thus this petition

Issues and Holdings:

1. W/N the death of Jacinto is a result of a willful act attributable to him and thus, not compensable?
The death of Jacinto is not compensable because it was a deliberate act of killing
himself by jumping into the sea as substantially proven by Crewlink. Willful Act. Edithas
claim on insanity as caused by homesickness and/or family problems may result to
depression does not necessarily equate to mental disorder. The issue of insanity is a
question of fact. It requires an opinion testimony which may be given by a witness who is
intimately acquainted with the person claimed to be insane, or who has rational basis to

conclude that a person was insane based on the witness own perception the person, or
who is qualified as an expert, such as a psychiatrist. No such evidence was presented to
support respondent's claim to Death Benefits of the Employee
The issue for resolution here is the obligation of the employer to its employee
based on contract of employment and not one of contract of carriage. Indeed, in order to
avail of death benefits, the death of the employee should occur during the effectivity of
the employment contract. This rule, however, is not absolute. The employer may be
exempt from liability if it can successfully prove that the seaman's death was directly
attributable to his deliberate or willful act as stated in No. 6, Section C, Part II of the
POEA-SEC.
While it is true that labor contracts are impressed with public interest and the
provisions of the POEA-SEC must be construed logically and liberally in favor of
Filipino seamen, still the rule is that justice is in every case for the deserving, to be
dispensed with in the light of established facts, the applicable law, and existing
jurisprudence
Ruling:
The petition is GRANTED. The Decision of the CA and its resolution denying the motion for
reconsideration are REVERSED and SET ASIDE. The Resolutions of the NLRC are hereby
REINSTATED and AFFIRMED.
Note:
VELASCO, JR., J Chairperson, ABAD, MENDOZA, and PEREZ, JJ., concur.