FACTS:

Petitioner Sea Power Shipping Enterprises, Inc. hired Warren M. Sabanal as Third Mate onboard MT Montana. While onboard, Sabanal started exhibiting unusual behavior and eventually jumped into the sea and drowned. Seapower informed Sabanal's wife, Elvira, of the incident but initially did not provide clear information on her entitlement to benefits. After learning that she was only entitled to death benefits under the Social Security System, Elvira filed a complaint for payment of Sabanal's death benefits. Seapower denied any liability, claiming that Sabanal's death was a result of suicide. The Labor Arbiter dismissed Elvira's case on the grounds of prescription and lack of merit, while the NLRC affirmed the dismissal based on Sabanal's willful act. The Court of Appeals, however, reversed the NLRC's decision, finding that Sabanal's actions were not willful disregard of his safety but rather a result of paranoia. Seapower now questions whether Sabanal's death is compensable based on the exemptions provided in the POEA-SEC.

ISSUES:

1. Whether the exemption of the employer from liability for death or injury resulting from the seafarer's willful act extends to the case when the seafarer had been acting strangely prior to jumping into the sea.

RULING:

1. The Court of Appeals ruled that Sabanal's death is compensable. The Court held that Sabanal's strange conduct prior to jumping off the ship indicates that his actions were not borne out of his willful disregard of his safety and life, but rather based on a belief that the ship was in grave danger and he wanted to save himself from the imagined doom. Therefore, Seapower is ordered to pay death benefits to Elvira.

PRINCIPLES:

• The employer is generally liable for death compensation benefits when a seafarer dies during the term of employment, unless the death was caused by an injury directly attributable to the seafarer's deliberate or willful act. (Part II, Section C(6) of the POEA-SEC)