AGILE MARITIME vs.

SIADOR

Dennis Siador, a Seaman aboard LNG Aries under Agile Maritime, fell overboard to his death
in the high seas.
His father is claiming for death benefits as Dennis was suffering a mental disability, and the
incident is not wilful
Agile contends that Dennis wilfully took his own life, evidenced by the refusal of Dennis to
grab the life ring which was thrown at him immediately after he jumped to the water.
Under POEA, the employer is not liable for the compensation if the death is directly
attributable to the seafarer.
NLRC dismissed, substantial evidence exists to prove Siadors claims.
CA reversed, no substantial evidence.

ISSUE: Was Agile able to prove that Dennis willfully took his life thus shifting the burden on Siador to
prove by substantial evidence that Dennis was insane at the time of incident?

RULING: Yes. The law requires the employer to prove not only that the death is directly
attributable to the seafarer himself but also that the seafarer willfully caused his death, however,
evidence of insanity or mental sickness may be presented to negate the requirement of willfulness
as a matter of counter-defense. Since Agile was able to establish their defense by substantial
evidence, the burden of evidence now shifts to the seafarers heirs.