Title
Ayungo vs. Beamko Shipmanagement Corp.
Case
G.R. No. 203161
Decision Date
Feb 26, 2014
Seafarer denied disability benefits due to failure to prove work-relatedness of illnesses, fraudulent misrepresentation in medical exam, and non-compliance with conflict-resolution procedure.
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Case Digest (G.R. No. 203161)

Facts:

    Employment and Pre-Employment Medical Examination

    • On October 11, 2007, Ayungo entered into a 12‑month Contract of Employment with Beamko Shipmanagement Corporation on behalf of Eagle Maritime RAK FZE, being engaged as Chief Engineer for the vessel M/V World Star.
    • On October 10, 2007, just prior to embarkation, Ayungo underwent a pre‑employment medical examination at the Sagrada Corazon Medical and Allied Services Center, Inc. (SCMASCI) where he disclosed that he had Diabetes Mellitus but denied having High Blood Pressure.
    • Despite the disclosure, the examining physicians (Dr. Janilyn M. Ong and Dr. Catalina P. Ricohermoso) declared him fit for sea duty.
    • Ayungo then boarded the vessel on October 14, 2007.

    Onset of Medical Incident at Sea

    • On the morning of March 15, 2008, while on duty in the engine room, Ayungo suddenly lost his sense of hearing except for a continuous ringing noise.
    • The vessel was nearing its destination in Yokohama, Japan, and despite the onset of symptoms, he continued working until 8:00 in the evening.
    • Shortly after, he experienced dizziness, vomiting, and lost consciousness, with his condition being noticed by a fellow crew member, Oiler Desiderio Sumalinog.
    • Following the incident, the master of the vessel was informed, leading to Ayungo’s confinement at the Yokohama Red Cross Hospital.

    Medical Diagnosis, Repatriation, and Subsequent Findings

    • After arriving in Yokohama on March 16, 2008, Ayungo was diagnosed with a sudden auditory disorder (auditory dysesthesia) and was later repatriated to the Philippines on March 25, 2008 for further treatment.
    • At the Metropolitan Medical Center (MMC), Beamko’s designated physician, Dr. Robert Lim, issued a Medical Certificate on March 26, 2008 noting possible Meniere’s Syndrome (Endolymphatic Hydrops), Hypertension, and Diabetes Mellitus; it was also noted that his Hypertension was a pre‑existing condition managed by the drug Lifezar.
    • Further evaluations on May 21, 2008 diagnosed him with Multiple Lacunar Infarcts and Coronary Artery Disease (CAD).
    • Later, on July 9, 2008, another report by Dr. Mylene Cruz‑Balbon and Dr. Lim reiterated that both his Hypertension and Diabetes Mellitus were pre‑existing and not work‑related.

    Filing of the Disability Benefits Claim and Subsequent Proceedings

    • On September 2, 2008, Ayungo filed a complaint before the National Labor Relations Commission (NLRC) for permanent total disability benefits, sickness allowance, reimbursement of medical expenses, damages, and attorney’s fees against Beamko, its representative Juanito G. Salvatierra, Jr., and Eagle Maritime.
    • In his Position Paper dated February 4, 2009, Ayungo asserted that he was entitled to benefits on the basis that:
    • His Hypertension had impaired his heart and kidneys.
    • His Hypertension and CAD developed or were aggravated by the conditions of his employment.
    • The employer assumed the risk by hiring him despite his disclosure of having Diabetes Mellitus.
    • Respondents countered that his illnesses were pre‑existing and not related to the performance of his duties as per the 2000 POEA Standard Employment Contract.
    • The Labor Arbiter (LA), in a decision dated May 14, 2009, ordered the payment of permanent total disability benefits, sickness allowance, moral and exemplary damages, and attorney’s fees, rejecting the contention that his pre‑existing conditions exempted the respondents from liability.
    • The NLRC, in its Resolution dated July 20, 2010, affirmed the LA’s ruling. After a motion for reconsideration was also denied on September 28, 2010, Ayungo filed a petition for certiorari before the Court of Appeals (CA).
    • The CA, in its Decision dated May 4, 2012, set aside the NLRC’s decision, holding that Ayungo failed to establish a causal link between his pre‑existing illnesses and his work.
    • A subsequent motion for reconsideration before the CA was denied in a Resolution dated August 16, 2012, leading to the present petition.

Issue:

  • Whether the Court of Appeals erred in granting respondents’ petition for certiorari which set aside the NLRC’s decision granting Ayungo disability benefits.
  • Whether Ayungo sufficiently demonstrated the causal connection between his pre-existing conditions (Diabetes Mellitus and Hypertension) and the performance of his employment duties as Chief Engineer.
  • Whether the NLRC erred by finding, without substantial evidence, that the work conditions contributed to aggravating his pre‑existing conditions, thereby making them compensable under the 2000 POEA Standard Employment Contract.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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