Title
Albarracin vs. Philippine Transworld Shipping
Case
G.R. No. 210791
Decision Date
Nov 19, 2018
Seafarer’s death from HCC deemed non-compensable as illness occurred post-contract, with insufficient evidence linking it to work conditions.
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Case Digest (G.R. No. 210791)

Facts:

Employment and Medical Examination:

  • Rex Miguelito Albarracin (Albarracin) was hired by Philippine Transworld Shipping Corp. (Transworld) on September 5, 2006, as Second Officer on board the vessel M/T Eastern Neptune under a Philippine Overseas Employment Agency-Standard Employment Contract (POEA-SEC).
  • Despite an abnormal pre-employment medical examination (PEME) showing "uninterpretable STT wave changes for ischemia due to left ventricular hypertrophy," Albarracin was declared "fit for sea duty."

Repatriation and Illness:

  • Albarracin completed his 9-month contract and returned to the Philippines on May 22, 2007. He underwent another PEME on July 18, 2007, which revealed Hepatitis B and suspected Hepatocellular Carcinoma (HCC).
  • Albarracin died on March 31, 2008, leaving behind his wife, Daylinda Albarracin (petitioner), and a minor child.

Claims and Denials:

  • The petitioner filed a complaint for death benefits, medical expenses, and attorney’s fees, alleging that Albarracin’s work exposed him to toxic substances, contributing to his illness.
  • Respondents denied liability, arguing that Albarracin’s death occurred after his contract expired, his illness was not work-related, and he failed to undergo a post-employment medical examination within three days of disembarkation.

Labor Arbiter and NLRC Decisions:

  • The Labor Arbiter dismissed the complaint, ruling that Albarracin’s death was not work-related and occurred after his contract ended.
  • The NLRC reversed the Labor Arbiter’s decision, finding that Albarracin’s illness was work-related and compensable under the POEA-SEC.

Court of Appeals Ruling:

  • The CA reinstated the Labor Arbiter’s decision, ruling that Albarracin’s HCC was caused by Hepatitis B, which is not work-related, and that the NLRC erred in applying the presumption of compensability.

Issue:

  1. Whether the Court of Appeals erred in reversing the NLRC’s decision and ruling that Albarracin’s death was not compensable.
  2. Whether Albarracin’s illness, Hepatocellular Carcinoma (HCC), is work-related and presumed compensable under the POEA-SEC.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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