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Equal Protection in Maritime Law

The Conference of Maritime Manning Agencies Inc challenged a POEA resolution and circular that increased death benefits for Filipino seafarers, claiming it violated equal protection. The Supreme Court ruled that the increased benefits did not violate equal protection because there are substantial distinctions between seafarers and land-based overseas workers given the dangers of working at sea. The petition was dismissed.

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Namiel Maverick D. Balina
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152 views1 page

Equal Protection in Maritime Law

The Conference of Maritime Manning Agencies Inc challenged a POEA resolution and circular that increased death benefits for Filipino seafarers, claiming it violated equal protection. The Supreme Court ruled that the increased benefits did not violate equal protection because there are substantial distinctions between seafarers and land-based overseas workers given the dangers of working at sea. The petition was dismissed.

Uploaded by

Namiel Maverick D. Balina
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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G.R. No.

114714 April 21, 1995

The Conference of Maritime Manning Agencies Inc v. POEA

MAIN TOPIC – Equal Protection

I. FACTS
 The Government Board of Philippines Overseas Employment Administration (POEA) issued Resolution No.
01, issued on 14 January 1994 amending and increasing the other compensation and other benefits as specified
under Part II, Section. C, paragraph 1 and Section L, paragraphs 1 and 2 of the POEA Standard Employment
Contract for Seafarers that in case of death of the seaman during the term of his Contract, the employer shall
pay his beneficiaries the Philippine Currency equivalent to the amount of US$50,000 and an additional amount
of US$7,000 to each child under the age of twenty-one (21) but not exceeding four children at the exchange
rate prevailing during the time of payment.
 Also, Memorandum Circular No. 05, issued on 19 January 1994 was issued to inform all Filipino seafarers,
manning agencies, shipowners managers and principals hiring Filipino seafarers on the said adjustment.

II. ISSUE
Whether or not the assailed issuances of Governing Board Resolution No. 01, issued on 14 January 1994 and
Memorandum Circular No. 05, issued on 19 January 1994 violated the equal protection clause of the Constitution

III. HELD
No. The Court held that to support its contention of inequality, the petitioners claim discrimination against foreign
shipowners and principals employing Filipino seamen and in favor of foreign employers employing overseas Filipinos
who are not seamen. There can be no dispute about the dissimilarities between land-based and sea-based Filipino
overseas workers in terms of, among other things, work environment, safety, dangers and risks to life and limb, and
accessibility to social, civic, and spiritual activities.

IV. DISPOSITIVE PORTION


WHEREFORE, for lack of merit, the instant petition is DISMISSED with costs against the petitioners. SO ORDERED.

V. DOCTRINE
It is an established principle of constitutional law that the guaranty of equal protection of the laws is not violated by
legislation based on reasonable classification. And for the classification to be reasonable, it (1) must rest on substantial
distinctions; (2) must be germane to the purpose of the law; (3) must not be limited to existing conditions only; and (4)
must apply equally to all members of the same class.

Ponente: Davide Jr. J.

Digest Maker: Balina, Namiel Maverick

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