G.R. No. 206032 - Bautista vs. Elburg Shipmanagement Philippines, Inc.

On August 7, 2008, petitioner Jose Rudy L. Bautista entered into a nine-month employment contract with respondent Elburg Shipmanagement Philippines, Inc. on behalf of its foreign principal, Augustea Shipmanagement Italy.
Petitioner was designated as Chief Cook for the vessel "MV Lemno" and underwent a Pre-Employment Medical Examination (PEME), where he was certified fit for sea duty by the company-designated physician before his embarkation on August 14, 2008.

During his employment, petitioner experienced symptoms including breathing difficulty, weakness, severe fatigue, dizziness, and grogginess.
These symptoms led to his referral to a portside hospital where he was initially suspected to have a "thoracic aneurysm," prompting medical repatriation on May 8, 2009.
After repatriation, further medical evaluation at Metropolitan Medical Center (MMC) revealed that while thoracic aneurysm was ruled out, petitioner was diagnosed with "Hypertensive Cardiovascular Disease" and "Diabetes Mellitus II."

On September 4, 2009, the company-designated physician, Dr. Melissa Co Sia, issued a working impression diagnosing petitioner with "Hypertension," "Dyslipidemia," and "Chronic Obstructive Pulmonary Disease," while stating that petitioner would be cleared for duty pending stabilization of his blood pressure and lipid levels.
Petitioner later filed a complaint on September 16, 2009 against the respondents, seeking total and permanent disability benefits under the applicable Collective Bargaining Agreement (CBA), damages, and attorney’s fees.
In his complaint, petitioner asserted that:

His illnesses were occupational in nature, having been developed, enhanced, and aggravated by his work environment and the inherent risks of his job as Chief Cook.
He was unable to return to work within 120 days, rendering his disability both permanent and total.

Petitioner attached a medical certificate and evaluation by his own physician, Dr. Efren R. Vicaldo, which opined that petitioner's illnesses (“Hypertensive atherosclerotic cardiovascular disease” and “Diabetes mellitus”) rendered him unfit to function as a seaman and were work-related or work-aggravated.
Respondents countered by asserting that the Diabetes Mellitus II was familial or genetic and not work-related, and that the Hypertensive Cardiovascular Disease was merely a complication of the diabetes, thereby disassociating it from occupational causation.

The Labor Arbiter ruled in petitioner’s favor on February 19, 2010, ordering the payment of US$89,100.00 for total and permanent disability benefits (plus attorney’s fees), relying substantially on the medical evidence and the presumption of incapacity due to the duration (exceeding 120 days) of the ailment.
The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision in a ruling dated September 20, 2010, emphasizing that although Diabetes Mellitus II is not compensable as an occupational disease, the finding of Hypertensive Cardiovascular Disease under Section 32-A of the POEA-SEC was sufficient to award benefits.
Respondents moved for reconsideration, which was denied on December 20, 2010, leading to the issuance of an entry of judgment against them.
The Court of Appeals (CA) later granted respondents’ petition for certiorari in a decision dated September 6, 2012, dismissing petitioner’s claim on the grounds that inadequate substantial evidence linked his Hypertension and Cardiovascular Disease directly with his employment, and questioned the credibility and timing of Dr. Vicaldo’s evaluation.
Petitioner sought reconsideration before the CA, which was denied in a resolution dated February 19, 2013, prompting the present petition for review.

Whether the CA erred in holding that petitioner failed to establish by substantial evidence that his Hypertensive Cardiovascular Disease was contracted and aggravated during his employment as Chief Cook.

Does the medical evidence, including that provided by both the company-designated physician and Dr. Vicaldo, suffice to establish a causal relationship between petitioner’s disease and his employment?
Should statutory and contractual provisions, particularly those under the 2000 POEA-SEC and the Collective Bargaining Agreement, govern the compensability of a work-related occupational disease even if the illness resulted from multiple contributing factors?

Whether the so-called “120-day rule” can be applied as an absolute measure in determining entitlement to maximum disability benefits, or if it is subject to the circumstantial context of the case.