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  • 02 Wallem Maritime v. Pedrajas

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    Jet Siang
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    This case summarizes a dispute over death benefits following the death of Hernani Pedrajas, an employee of Wallem Maritime Services, who was found dead onboard a ship in Italy. The Italian authorities concluded it was suicide based on forensic evidence and suicide notes. However, Philippine authorities were inconclusive. The Supreme Court ruled that (1) the Italian investigation had more weight given its definitiveness and access to evidence; (2) the suicide notes were admissible despite being photocopies, as technical rules of evidence do not strictly apply, and they provided strong proof of suicide based on consistent handwriting and corroboration. Therefore, Wallem Maritime did not have to pay death benefits as the death was ruled a suicide

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    Case Digest Wallem Maritime vs Pedrajas

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    This case summarizes a dispute over death benefits following the death of Hernani Pedrajas, an employee of Wallem Maritime Services, who was found dead onboard a ship in Italy. The Italian authorities concluded it was suicide based on forensic evidence and suicide notes. However, Philippine authorities were inconclusive. The Supreme Court ruled that (1) the Italian investigation had more weight given its definitiveness and access to evidence; (2) the suicide notes were admissible despite being photocopies, as technical rules of evidence do not strictly apply, and they provided strong proof of suicide based on consistent handwriting and corroboration. Therefore, Wallem Maritime did not have to pay death benefits as the death was ruled a suicide

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    314 views2 pages

    02 Wallem Maritime v. Pedrajas

    Uploaded by

    Jet Siang
    This case summarizes a dispute over death benefits following the death of Hernani Pedrajas, an employee of Wallem Maritime Services, who was found dead onboard a ship in Italy. The Italian authorities concluded it was suicide based on forensic evidence and suicide notes. However, Philippine authorities were inconclusive. The Supreme Court ruled that (1) the Italian investigation had more weight given its definitiveness and access to evidence; (2) the suicide notes were admissible despite being photocopies, as technical rules of evidence do not strictly apply, and they provided strong proof of suicide based on consistent handwriting and corroboration. Therefore, Wallem Maritime did not have to pay death benefits as the death was ruled a suicide

    Copyright:

    © All Rights Reserved
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    of 2

    Wallem Maritime Services et al. v.

    Donnabella Pedrajas and Sean Jade Pedrajas


    (2014) Peralta.
    FACTS:
    (1) Petitioner Wallem Maritime Services employed Hernani Pedrajas, the spouse and
    father of the respondents, respectively, as Engine Boy on the M/V Crown Jade
    deployed in Italy.
    (2) Hernani was found dead onboard; cause of death was allegedly by hanging.
    (3) An investigation conducted by Italian authorities concluded:
    a. Cause of death was suicide by hanging
    b. Hernani had been involved in a drug deal together with a Deck Boy Joseph
    Harder
    c. Evidence included
    i. Authenticated copy of forensic report by Italian authorities
    ii. Suicide notes; copies of which given to the families but the
    originals remained in Italy.
    d. No other injuries on the person of Hernani, and white paint from the deck
    railing was found on his hands, which lends to the conclusion that he tied the
    rope himself.
    (4) Due to the cause of death being suicide, Willem Maritime did not pay death
    benefits in accordance with their POEA Standard Employment Contract.
    (5) Respondents challenged this and asked the PNP and NBI to conduct their own
    investigation
    a. PNP and NBI concluded that homicide cannot be ruled out but admitted data
    was insufficient
    (6) Rulings
    a. LA: Ruled that the death was self-inflicted. No need to pay death benefits.
    b. NLRC: Reversed LA. Not proven that it was suicide. Burden of proof on
    employer.
    c. CA: Affirmed NLRC. PNP/NBI reports weakened the conclusions of Italian
    authorities.
    (7) RE suicide notes
    a. CA: Did not give high probative weight to suicide notes because they were
    not proven to be in the deceaseds handwriting
    b. Respondents: Argue that they are not even admissible for being mere
    photocopies.
    ISSUES:
    (1) Which investigation/findings has more weight, Italian or PH authorities? [Italian]
    (2) Are the suicide notes admissible? [Yes] What was the probative weight? [strong proof
    of suicide]
    SC RULED:
    RE investigations: More credence to Italian authorities
    (1) Italian authorities report was more categorical/definite, and based on a thorough first
    hand investigation with more access to the evidence (which they still held).
    (2) On the other hand, PNP/NBI reports were inconclusive and based on second hand
    verbal information from the relatives.
    RE Admissibility of Suicide Notes
    (1) Yes they are admissible the fact that they are mere photocopies are of no moment.
    The technical rules of evidence do not apply to proceedings of the LA/NLRC. They are
    to use all reasonable means to ascertain the facts of each case speedily and
    objectively without regard to the technicalities of law and procedure in the interest of
    substantial justice.
    (2) Also, there was good reason why the originals not presented; Italian authorities had
    yet to release them.

    RE probative weight of Suicide Notes


    (1) Handwriting and terminologies between the two notes were consistent as to suggest
    that they were written by the same person.
    (2) Handwriting in notes also compared with other letters. LA concluded that they were
    consistent. CA should have taken them into account.
    (3) Information narrated in the notes corroborated by the Deck Hand who was the
    accomplice in the drug deal.
    Since information in the notes proved to be
    informative and useful to Italian authorities, it would only lend more credence to their
    genuineness and truthfulness.

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