Facts:

Joemar Babiera Bacabac (petitioner) entered into an employment contract with NYK-FIL Shipmanagement Inc., a local manning agency, representing its principal NYK Shipmanagement Pte Ltd. (respondents), on November 25, 2011. Subsequently, he was deployed on board the vessel MV IKI for nine months starting December 8, 2011. On March 11, 2012, while performing his duties, Joemar experienced dizziness and abdominal pain. Despite reporting his condition to the Second Officer and receiving medications, his symptoms worsened, culminating in him vomiting blood upon the vessel's arrival in Chile a few days later. Joemar was then transferred to Clinica Sanatorio Aleman, where it was discovered that his kidneys were not functioning properly, leading to him undergoing dialysis three times. Further medical interventions included surgery to remove stones in his bile duct. After more than two months of hospitalization from March 15, 2012, to May 19, 2012, Joemar was medically repatriated to

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Facts:

Employment and Contractual Background

• Joemar Babiera Bacabac was hired by NYK-FIL Shipmanagement Inc. on November 25, 2011, as an oiler, with the employment being managed on behalf of its principal, NYK Shipmanagement Pte Ltd.
• The employment contract was governed by the POEA-Standard Employment Contract, specifically set under the 2010 Amended Standard Terms and Conditions Governing the Overseas Employment of Filipino Seafarers On-Board Ocean-Going Ships.
• Joemar was deployed on board the vessel MV IKI on December 8, 2011, for a period of nine months, running until September 8, 2012.

Incident and Medical Treatment

• On March 11, 2012, while performing his duties in the engine room, Joemar felt dizzy and suffered abdominal pain.
• He reported the incident to the Second Officer and initially received medicines; however, his symptoms persisted, leading to further complications.
• Upon the vessel's arrival in Chile, Joemar vomited blood and was promptly taken to the nearest clinic, then transferred to Clinica Sanatorio Aleman.
• Medical findings revealed that his kidneys were malfunctioning, necessitating three dialysis sessions, accompanied by surgery to remove stones in his bile duct.
• Joemar was subsequently confined in the hospital for over two months (from March 15, 2012, to May 19, 2012).
• On May 21, 2012, he was medically repatriated and admitted to Manila Doctor’s Hospital, where he underwent further procedures including a duodenostomy and an endoscopy.
• On May 23, 2012, a company-designated physician diagnosed him with Severe Acute Cholangitis, stating that his condition was not work-related.
• Treatment costs were shouldered by the respondents, and Joemar was finally discharged on June 19, 2012.

Prior Proceedings and Judicial History

• On September 24, 2012, Joemar filed a complaint before the labor arbiter, seeking total and permanent disability benefits, sickness allowance, reimbursement for medical and hospital expenses, moral and exemplary damages, and attorney’s fees.
• The labor arbiter, on April 15, 2013, ruled in Joemar’s favor by awarding him full disability benefits and sickness allowance on the presumption that his illness was work-related.
• The respondents appealed the decision; on November 29, 2013, the National Labor Relations Commission (NLRC) reversed the decision, dismissing the complaint on the grounds that Joemar’s illness was not work-related and that he failed to establish a reasonable connection between his work and the illness.
• After an unsuccessful reconsideration, Joemar elevated the case to the Court of Appeals (CA) through a Petition for Certiorari (CA-G.R. SP No. 134377), where on April 27, 2016, the CA affirmed the NLRC’s reversal.

Joemar’s Claims and Arguments

• Joemar argued that since his illness manifested while he was on board the vessel—within the term of his employment contract—it is presumptively work-related under the POEA-SEC.
• He stressed his entitlement to total and permanent disability benefits and corresponding sickness allowance, asserting that the respondents failed to provide conclusive evidence countering the work-related nature of his illness.
• The contentious issue also involved the inadequacy of the company-designated physician’s medical report, which he maintained was incomplete, as it quickly declared his condition not work-related without sufficient justification, especially given his continued hospitalization.

Issue:

Causal Connection Between Employment and Illness

• Whether Joemar’s Severe Acute Cholangitis, which manifested during his active employment on the vessel, can be presumed as work-related under the POEA-SEC guidelines.
• The sufficiency of evidence to establish the required causal link between his work and his illness.

Validity and Adequacy of the Company Physician’s Report

• Whether the company-designated physician’s report, which declared the illness as not work-related, meets the required standard of a complete and definitive medical evaluation.
• If the report properly reflects the extent of Joemar’s sickness or injury and fulfills the established legal parameters for verifying work-related disability.

Entitlement to Benefits

• Whether Joemar is entitled to total and permanent disability benefits and sickness allowance given that his illness manifested during the term of his contract and his complaint was filed within the required 120-day period following repatriation.
• How the integration of the POEA-SEC with the employment contract affects the determination of his benefits despite the early medical opinion of non-compensation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)