G.R. No. 215925 - Gaoiran vs. Court of Appeals

Respondent Jerry J. Racela was hired on March 21, 2013 by petitioner Bright Maritime Corporation to serve as a fitter on board a vessel owned by Norbulk Shipping UK Limited.
His employment contract provided detailed terms including an 8-month duration (with a possible extension), a basic monthly salary of US$600.00, overtime and supplementary wage provisions, as well as specific work hours and rest periods.
He was also covered by a Collective Bargaining Agreement (CBA) between Norbulk Manning Services Limited and the Latvian National Seafarers Trade Union.
Prior to deployment, Racela underwent a Pre-Employment Medical Examination (PEME) and was declared “Fit for Sea Duty as Engine Rating.”

In February 2014, while already employed on board, Racela experienced chest pains and difficulty breathing, leading to his admission to Alisha Hospital in Israel on March 23, 2014.
He was diagnosed with pulmonary edema, severe aortic regurgitation, and an aneurysm of the sinuses of Valsalva, and subsequently underwent open-heart surgery (aortic valve replacement) on March 25, 2014.
After surgery, he was medically repatriated on April 19, 2014 and was immediately confined at the Chinese General Hospital for further evaluation.
During follow-up checkups with the company-designated physician, Racela reported persistent symptoms including pain at the surgical site and a clicking sound; he was re-assessed and his condition was later termed “aortic valve stenosis.”
On May 2, 2014, a cardiologist recommended additional tests (e.g., repeat 2D Echocardiography and retrieval of angiogram results) and continuation of medication, while subsequent evaluations by the company-designated physician maintained that no disability grading was given since the condition was pre-existing or hereditary.
On August 26, 2014, Racela underwent coronary angiography, the results of which were briefly noted but never fully clarified by the company-designated physician.

On June 9, 2015, Racela filed a disability complaint against the petitioners claiming that he was not adequately informed of the company-designated physician’s assessment regarding his fitness for sea duty.
He sought total disability benefits (initially US$60,000.00), along with moral and exemplary damages and attorney’s fees.
Petitioners contended that Racela had been informed—in a meeting with company representatives—about his condition and the limits of medical treatment, and that he even received approval for the cost of his coronary angiogram when he requested it.
Subsequent correspondence between Racela’s counsel and petitioners revealed disagreements regarding whether Racela truly understood the medical findings, with petitioners asserting compliance with the mandatory referral process and Racela alleging non-referral to an independent third doctor.
The labor dispute culminated at the National Labor Relations Commission (NLRC) and eventually escalated through a Labor Arbiter’s decision, followed by appeals.

The Labor Arbiter, in his April 19, 2016 decision, ruled in favor of Racela by awarding him total and permanent disability benefits and attorney’s fees based on the argument that:

The language in the employment contract and CBA was permissive (using “may”) regarding the referral to a third doctor.
The ongoing payment of sickness allowance and continued medical treatment implicitly admitted the work-related nature of his condition.
Racela’s condition, which remained unresolved, rendered him totally and permanently disabled.

Racela failed to present substantial evidence linking his heart disease causally to his work as a fitter.
Medical literature pointed to natural causes of aortic valve stenosis (e.g., genetics, aging) and disputed its association with occupational hazards.
Dr. Vicaldo’s opinion was not given full credence because it was based on limited testing and did not sufficiently establish work-relatedness.

The Court of Appeals (CA) reversed the NLRC’s ruling by reinstating the Labor Arbiter’s award of disability benefits.
In its decision, the CA determined that:

There was a causal relationship between Racela’s work conditions—including long hours, exposure to harsh environmental factors, and strenuous physical activities—and the aggravation of his cardiac condition.
The absence of a definite disability rating by the company-designated physician, coupled with the prolonged unresolved state of his medical condition, warranted the presumption of total and permanent disability.
Judicial notice was taken that seafarers are subject to the physical and mental strains of maritime work, which supports the contention that cardiovascular diseases are compensable as work-related injuries under the POEA-SEC and the CBA.

Whether Racela’s cardiovascular disease, particularly aortic valve stenosis, is causally related to the nature of his work as a fitter on board petitioners’ vessel.
Whether his pre-existing or congenital condition was aggravated by occupational exposures and strenuous activities encountered during his employment.

Whether the company-designated physician’s failure to award a definitive disability grading or to provide a conclusive fitness-to-work assessment within the prescribed 120/240-day period should lead to a presumption of total and permanent disability under the POEA-SEC.
Whether Racela’s pursuit of a second opinion (Dr. Vicaldo) and subsequent non-referral to a third doctor (as contemplated in the employment contract and POEA-SEC) affects his claim for benefits.

Whether Racela has met the substantial evidence standard required to establish the necessary causal connection between his heart disease and his employment conditions.
Whether the identified medical discrepancies and ambiguities (e.g., the results of coronary angiography and conflicting assessments) justify awarding disability benefits.