Title
Balba vs. Tiwala Human Resources, Inc.
Case
G.R. No. 184933
Decision Date
Apr 13, 2016
Seafarer's death from cancer deemed non-compensable as it occurred post-contract, with no proven work-related causation under POEA-SEC.
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Case Digest (G.R. No. 184933)

Facts:

  1. Employment Contract and Medical Examination

    • In 1998, Rogelio Balba entered into a 10-month employment contract with Tiwala Human Resources, Inc. for its foreign principal, Togo Maritime Corporation, as chief cook on board the vessel M/V Giga Trans.
    • He was declared fit for work in his pre-employment medical examination and boarded the vessel on November 13, 1998.
  2. Repatriation and Illness

    • Upon the expiration of his contract, Rogelio was repatriated to the Philippines in October 1999.
    • From October to November 1999, he was treated by Dr. Benito Dungo for weakness and numbness in his left half body and lower extremities, diagnosed with moderately severe diabetes.
    • In 2000, Rogelio was confined at the Seamen's Hospital and diagnosed with metastatic cancer. He sought disability compensation and benefits from the respondents, which were denied.
  3. Filing of Complaint and Death

    • On April 6, 2000, Rogelio filed a complaint against the respondents for disability benefits, damages, and attorney's fees.
    • On April 28, 2000, Rogelio was admitted to the Philippine General Hospital for lung cancer and succumbed to his illness in July 2000.
    • Following his death, his wife, Violeta Balba, and their two minor children, Roy and Vienna Gracia, were substituted as complainants.
  4. Labor Arbiter (LA) Ruling

    • On September 25, 2002, the LA dismissed the complaint, ruling that Rogelio's death was not compensable under the POEA-SEC.
  5. NLRC Ruling

    • On December 28, 2004, the NLRC reversed the LA's decision, declaring that Rogelio contracted his illness while on board the vessel and during the existence of his contract. It awarded death benefits, burial benefits, and attorney's fees.
  6. Court of Appeals (CA) Ruling

    • On May 31, 2007, the CA reversed the NLRC's decision, finding no evidence linking Rogelio's cancer to his work as chief cook.

Issue:

  • Whether the CA committed grave abuse of discretion in granting the respondents' petition for certiorari and denying the petitioners' motion for reconsideration by reversing and setting aside the NLRC decision awarding death benefits under the POEA-SEC.

Ruling:

The Supreme Court ruled in favor of the respondents, affirming the CA's decision. The Court held that:

  1. Rogelio's death occurred almost ten months after the expiration of his contract and nine months after his repatriation, making it non-compensable under Section 20(A) of the 1996 Revised POEA-SEC.
  2. The petitioners failed to provide sufficient evidence to establish a causal connection between Rogelio's illness and his employment.
  3. The principle of liberality in favor of seafarers cannot be applied when the evidence negates compensability.

Ratio:

  • (Unlock)

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