G.R. No. 103974 - People vs. Catanyag y Sta. Ana

The respondent, Eberly S. Alcayno, was employed as an Able-bodied Seaman by Fuyo Kaiun Co. Ltd. through its local manning agent, Barko International, Inc.
His employment contract provided for a nine-month period, a basic monthly salary of US$539.00, fixed overtime pay of US$401.00, and vacation leave with pay.
His duties included painting, chipping rust on the ship’s deck or superstructure, and supervising cleaning operations on the vessel, M/V Cape Iris.

After boarding the vessel on December 1, 2005, the respondent developed symptoms including a stiff neck and swelling of the right jaw.
Within a month on board, his condition worsened despite medications, leading to his signing off on February 2, 2006, at the Suez Canal for medical attention.
A preliminary examination by Dr. Michael H. Mohsen revealed a firm mass on the left side of the neck, severe diffuse infection with pus collection, gangrene, necrosis of the neck tissues, uncontrolled diabetes mellitus, and signs suggestive of chronic disease or malignancy.
The medical report recommended hospital confinement for further treatment including drainage, antibiotic therapy, and blood sugar monitoring.

On February 8, 2006, the respondent was repatriated to the Philippines after being stabilized on board.
Upon arrival, he was examined by Dr. Nicomedes G. Cruz, a company-designated physician, who diagnosed him with uncontrolled diabetes mellitus and tuberculous adenitis.
A private physician, Dr. Regina Pascua Barba, later confirmed the diagnosis and recommended continuous treatment until January 2007.

The respondent filed his complaint on July 6, 2006 seeking disability benefits, reimbursement of medical expenses, payment for the unexpired portion of his contract, as well as moral, exemplary damages, and attorney’s fees.
The Labor Arbiter (LA) issued a decision on April 10, 2007 awarding permanent and total disability benefits, medical expenses, and attorney’s fees to the respondent based on the finding that his illness was work-related and incapacitated him for more than 120 days.

On November 29, 2007, the National Labor Relations Commission (NLRC) reversed the LA decision, holding that there was no sufficient factual or legal basis to find the respondent’s tuberculous adenitis and diabetes mellitus as compensable illnesses acquired during the short period of his employment.
The NLRC doubted the link between his working conditions and the development of his illnesses, also questioning why the respondent did not seek a second opinion to counter the company-designated physician’s evaluation.

The CA reversed the NLRC resolution, emphasizing that a seafarer’s continuous inability to work for more than 120 days is indicative of a permanent total disability, even if a company-designated physician declared him fit to work within that period.
The CA found that the hazardous working conditions, including exposure to paints, thinners, and other chemicals, likely contributed to the aggravation of his illness.
The petitioners’ motion for reconsideration, which cited the case of Vergara, was denied by the CA on the basis that the Vergara ruling was prospective and not applicable to the period when the claim accrued.

The petition for review on certiorari was ultimately denied by the Supreme Court.
The Court affirmed the factual findings of the LA as upheld by the CA, including the substantial evidence supporting the respondent’s claim of permanent total disability.
Notably, the Court underscored that the burden of proof in labor cases rests on the employee and that the continuous inability to work for more than 120 days—coupled with the work-related nature of the illness—justified the award of disability benefits.

Whether the respondent’s illnesses, specifically tuberculous adenitis and diabetes mellitus, were acquired in the course of his employment and are therefore compensable as work-related conditions.
Whether a seafarer’s inability to work for a period exceeding 120 days constitutes a permanent total disability in spite of a company-designated physician declaring him fit to work within the prescribed period.
Whether the reversal of the NLRC’s resolution by the Court of Appeals, and the subsequent awarding of permanent disability benefits along with attorney’s fees, complies with established labor and maritime employment jurisprudence.
Whether the petitioners’ reference to the Vergara ruling is applicable given the timing and circumstances of the present case.