G.R. No. 223246 - De Vera vs. United Philippine Lines, Inc.

Petitioner Tomas P. Atienza was employed as an Able Seaman by respondent Orophil Shipping International Co., Inc. on behalf of its principal, Hakuho Kisen Co., Ltd.
He was assigned to the M/V Cape Apricot, thereby exposing him to the rigors and hazards of sea duty.

During his employment, petitioner experienced severe headaches, nausea, and double vision while on board. These symptoms were later diagnosed by foreign port doctors as right cavernous sinus inflammation or Tolosa Hunt Syndrome (THS).
As a consequence of his deteriorating health, petitioner was repatriated on February 4, 2005.
Upon arrival, he was referred to a company-designated physician, Dr. Nicomedes G. Cruz, who confirmed the diagnosis and advised continuation of the medication prescribed abroad.
On June 28, 2005, Dr. Cruz issued a medical certificate declaring petitioner fit to resume work.
Unsatisfied with this assessment, petitioner sought a second opinion from an independent physician, Dr. Paul Matthew D. Pasco, who, in a subsequent medical certificate, classified petitioner’s condition as a Grade IV disability and declared him unfit for sea duty.

Petitioner filed a complaint before the National Labor Relations Commission (NLRC) seeking disability benefits, reimbursement of medical expenses, damages, and attorney’s fees against Orophil, Engineer Tomas N. Orola, and Hakuho.
In his complaint, petitioner asserted that the strenuous nature of his duties—including exposure to harsh environmental conditions and continuous on-call responsibilities—contributed to the aggravation of his pre-existing THS.

The Labor Arbiter (LA) ruled on April 30, 2007, in petitioner’s favor by awarding permanent disability benefits equivalent to US$34,330.00 for his Grade IV disability and 10% attorney’s fees, while dismissing other claims.
The NLRC, however, reversed the LA’s decision on April 22, 2008, dismissing petitioner’s complaint on the ground that he failed to establish that his illness was work-related and that the independent medical certificate lacked sufficient explanation.
The Court of Appeals (CA) affirmed the NLRC’s ruling on September 30, 2009, with a subsequent denial of a motion for reconsideration on January 22, 2010.
Petitioner elevated the matter to the Supreme Court through a petition for review on certiorari, arguing that grave abuse of discretion was committed by the NLRC (and by extension, the CA) in dismissing his claim for disability benefits.

Whether petitioner is entitled to total and permanent disability benefits under the 2000 POEA-SEC.
Whether there exists a reasonable connection between petitioner’s work as an Able Seaman and the aggravation of his pre-existing Tolosa Hunt Syndrome.
Whether the NLRC (and subsequently the CA) gravely abused its discretion by dismissing petitioner’s claim, particularly in light of the legal presumption of work-relatedness and the conditions for compensability.
Whether the failure of the company-designated physician to render a final assessment within the prescribed 120-day period should be given conclusive effect in determining permanent total disability.