G.R. No. 208215 - C.F. SHARP CREW MANAGEMENT, INC. vs. CASTILLO

Respondent was hired on June 6, 2008 by C.F. Sharp Crew Management, on behalf of Norwegian Cruise Line, Ltd., to serve as a Security Guard on board the vessel MV Norwegian Sun under a POEA‐approved employment contract for ten (10) months with a basic monthly salary of US$559.00.
Prior to deployment, respondent underwent a Pre-employment Medical Examination (PEME) and was pronounced fit for duty, although the PEME is not an in-depth exploration of an individual’s true state of health.

While on board, respondent experienced difficulty of breathing and suffered a brief seizure attack, causing him to fall from his bed.
Upon docking at Mazatlan, Sinaloa, Mexico, respondent was immediately admitted to a hospital where he was confined from September 24, 2008 to October 5, 2008; his condition was noted as a “right parietal hemorrhage” of the brain.

After repatriation on October 7, 2008, respondent was referred to company-designated physicians, Dr. Susannah Ong-Salvador and Dr. Antonio A. Pobre, for further evaluation.
An MRI conducted on October 20, 2008 revealed T1 and T2 weighted hyperdensity over the cortico-white matter junction of the right parietal lobe, pointing to an intracerebral hemorrhage possibly due to a small arterio-venous malformation or angioma.
Follow-up examinations and reports (January 9, February 9, March 2009) further evaluated his condition.
On April 16, 2009, Dr. Ong-Salvador issued a Medical Progress Report diagnosing “right parietal cavernoma” and opining that the condition was idiopathic (non-work-related). Shortly thereafter, on April 30, 2009, Dr. Pobre issued a certification stating that the cavernoma was congenital in nature and likewise not work-related.

Petitioners (employers) bore all expenses for respondent’s medical treatment.
Respondent was paid his sickness wages for the period from September 25, 2008 to April 30, 2009, as evidenced by the duly signed receipts.

On December 16, 2009, respondent filed a complaint for permanent and total disability benefits, damages, and attorney’s fees, alleging entitlement under the Norwegian Collective Bargaining Agreement (CBA) to a maximum compensation of US$120,000.00 based on his continued disability.
The Labor Arbiter dismissed the complaint on September 6, 2010, reasoning that although there was a disputable presumption regarding work-relatedness, respondent failed to overcome the certifications of the company-designated physicians—which clearly stated that his illness was idiopathic/congenital and not caused or aggravated by his work conditions.
The NLRC affirmed the Labor Arbiter’s Decision on January 25, 2011 and denied a motion for reconsideration on April 19, 2011.
The Court of Appeals (CA) reversed the NLRC’s decision on February 12, 2013, awarding respondent permanent and total disability benefits of US$60,000.00 along with attorney’s fees.
Petitioners filed a motion for reconsideration with the CA, which was denied in its Resolution dated July 10, 2013.

The case involved conflicting certifications: the company-designated physicians (Dr. Ong-Salvador and Dr. Pobre) opined that the illness was not work-related, while respondent’s personal physician, Dr. Vicaldo (who examined him only once and without further diagnostic testing), declared the illness as work-related.
Although the POEA-SEC provides a mechanism whereby, in cases of conflicting assessments, a third doctor may be jointly appointed to decide the matter, respondent did not avail himself of this option.

Petitioners argued that the NLRC and Labor Arbiter’s decisions, which relied on the certifications of company-designated physicians, should be given due deference.
They contended that the burden of proving work-relatedness rested on respondent, and the mere extension of disability beyond 120 days was insufficient for a finding of total and permanent disability without establishing a causative link between the illness and work.
Petitioners asserted that conflicting opinions among medical experts do not support the claim for disability benefits, and that the CA erred by overruling the public respondent’s (i.e., NLRC’s) reliance on the company physicians’ opinions.

Whether respondent’s cavernoma can be medically and legally deemed work-related given the conflicting opinions of the company-designated physicians and his personal physician.

Is there sufficient causal connection between the working conditions as a Security Guard and the development or aggravation of the respondent’s cavernoma?
Does the prolonged period of disability (exceeding 120 days) automatically warrant the grant of permanent and total disability benefits?

Whether the burden of proof regarding work-relatedness, as required by the POEA-SEC and relevant provisions of the Labor Code, was justly met by the respondent.

Must the respondent provide substantial evidence to overcome the disputable presumption as to work-relatedness?
What weight should be accorded to the testimonies and certifications of the company-designated physicians versus that of the respondent’s personal physician?

Whether the administrative bodies (NLRC and Labor Arbiter) properly exercised their discretion in dismissing the respondent’s claim, and whether the CA erred in reversing their decisions.