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
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
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
(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.