G.R. No. 97412 - Eastern Shipping Lines, Inc. vs. Court of Appeals

Respondent Mario H. Ong was first hired by petitioner BW Shipping Philippines, Inc. in January 1999 and was subsequently rehired and promoted several times over a nine‑year period.
On March 19, 2008, he was employed as Chief Steward and Chief Cook on board the vessel BW Hemina for a nine‑month period, with a basic monthly salary of USD1,127.00.
Prior to embarkation, he underwent the required physical and physiological evaluations by company‑designated physicians and was declared “fit for sea duty (without restriction).”

His duties included managing food supplies, supervising crew members’ meals, carrying supplies, and coordinating with port authorities and the principal company through reports and requests.
On June 8, 2008, while still aboard, respondent experienced symptoms such as dizziness, nausea, recurring headaches, body itchiness, frequent urination, and shortness of breath.
On June 17, 2008, a doctor in Tampa, Florida, diagnosed him with “uncontrolled diabetes and uncontrolled hypertension.”
He was repatriated on June 20, 2008, after which company‑designated physicians conducted further tests, advised the use of medications, and eventually declared him “fit to resume sea duties” on October 2, 2008.

Despite the company‑designated physicians’ clearance, respondent felt that his condition had not improved.
He sought a second opinion from his chosen doctor, Dr. Antonio C. Pascual, who, in a Medical Certificate dated January 12, 2009, diagnosed him with “Essential Hypertension, Stage 2 and Diabetes Mellitus, Type 2,” noting that there was no prior history of these illnesses.
Petitioners (BW Shipping Philippines, Inc. and associated parties) refused to defray the costs of his medications, prompting respondent to pursue legal remedies.

Respondent filed a complaint before the Labor Arbiter (LA) seeking permanent disability benefits, payment of medical reimbursement, damages, and attorney’s fees.
On June 19, 2009, LA Enrique L. Flores rendered a decision granting the complaint by awarding permanent total disability benefits of USD90,000.00 (in Philippine currency at the prevailing rate) and attorney’s fees amounting to ten percent (10%) of the award.
The LA ruled that the seafarer’s illness, to be compensable, needed only to occur during the contract, noting that his prolonged inability to return to work (over 241 days) validated his claim.

Petitioners appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC), which, on October 27, 2009, dismissed the appeal and affirmed the LA’s award.
The NLRC highlighted that compensability requires the illness to be not only contracted during employment but also work‑connected.
Petitioners sought reconsideration from the NLRC, but their motion was denied on December 22, 2009.
Subsequently, petitioners filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion in the NLRC’s approval of respondent’s remuneration.

On March 9, 2012, the CA issued a decision dismissing the petition for certiorari, thereby affirming the NLRC resolutions.
The CA reasoned that despite being declared fit to resume sea duty by the company‑designated physician, given the respondent’s continued inability to work (necessitating prolonged medication), the award of permanent total disability benefits was warranted.
Petitioners sought reconsideration before the CA, but their motion was denied in the CA Resolution dated June 4, 2012.

Petitioners then filed a petition for review on certiorari with the Supreme Court under Rule 45, contending that the CA committed grave abuse of discretion in sustaining the labor tribunal’s findings.
The central controversy revolved around the conflicting medical assessments: while company‑designated physicians had cleared the respondent for seafaring duties after proper evaluation and treatment, his private doctor’s diagnosis of advanced hypertension and diabetes was viewed as inadequately supported by medical evidence.
It was further emphasized that under the Philippine Overseas Employment Administration‑Standard Employment Contract (POEA‑SEC), a seafarer must comply with a prescribed conflict‑resolution mechanism when facing discrepant medical opinions—a procedure which the respondent failed to observe.

The determination of disability benefits is governed by both the employment contract and the POEA‑SEC, which require that the illness be work‑related and contracted during the term of employment.
Under Section 32‑A of the POEA‑SEC, diabetes mellitus is not classified as an occupational disease, whereas essential hypertension may be, provided it exhibits sufficient severity to impair bodily functions permanently.
The employer’s and company‑designated physicians’ evaluations, supported by timely and substantial medical evidence, formed the cornerstone of the dispute resolution in this case.

Whether the respondent’s claimed permanent total disability benefits for diabetes mellitus and essential hypertension are justified based on the evidence presented.

Does the respondent’s illness, as diagnosed by his private physician, satisfy the criteria of being both work‑related and contracted during the term of employment under the POEA‑SEC?

Whether the conflicting medical opinions between the company‑designated physicians and the respondent’s chosen doctor affect the entitlement to disability benefits.

What is the appropriate weight to give each set of medical findings, especially in light of the prescribed conflict‑resolution mechanism under the POEA‑SEC?

Whether grave abuse of discretion was committed by the lower tribunals (LA, NLRC, and CA) in awarding the disability benefits.

Are the findings and conclusions of the labor adjudicators supported by substantial evidence, particularly regarding the respondent’s work‑connection and the severity of his condition?

Whether the respondent complied with the procedural requirements under the employment contract and the POEA‑SEC when disputing the medical assessment provided by the company‑designated physicians.