G.R. No. 177874 - Ang vs. Court of Appeals

Alma Covita, acting on her own behalf and on behalf of her minor children, Jerry and Ron, is the petitioner.
The respondents include SSM Maritime Services, Inc., Maritime Fleet Services Pte. Ltd., and Gladiola Jalotjot.
Rolando Covita, the petitioner’s husband, entered into an employment contract with SSM Maritime Services, Inc. on April 29, 2009, for work aboard M/T Salviceroy as Bosun with a basic monthly salary of US$635.00.

As a condition of employment, Rolando underwent a Pre-employment Medical Examination (PEME), wherein he was declared fit for sea duty.
He reported for duty on May 7, 2009, beginning his contractual assignment.

On May 14, 2009, Rolando experienced weakness in both lower extremities and vomiting, prompting immediate hospital confinement at Singapore General Hospital until May 21, 2009.
He was diagnosed with end stage renal failure during his confinement in Singapore.
Subsequently, on May 23, 2009, he was medically repatriated to the Philippines and admitted at the Manila Doctor’s Hospital.
A company-designated physician, Dr. Nicomedes G. Cruz, diagnosed him with chronic renal failure and issued a certification on May 28, 2009 stating that the condition was not work-related.

Rolando Covita died on September 20, 2009.
Alma Covita filed a complaint before the Labor Arbiter (LA) seeking death benefits, allowances for the children, burial expenses, moral and exemplary damages, legal interest, and attorney’s fees.
The petitioner argued that despite his short assignment, the working conditions—including stress, heavy workload, and overfatigue—contributed to high blood pressure and ultimately to his renal failure, thus making the illness work-related.

The Labor Arbiter rendered a decision on November 26, 2010, awarding death benefits totaling US$75,000, reasoning that the illness had manifested during the contract period.
Private respondents filed an appeal with the National Labor Relations Commission (NLRC), which on March 30, 2011 reversed the LA decision and dismissed the claim for lack of merit.
The NLRC decision was based on:

The medical evidence indicating that chronic renal failure is a progressive disease that could not have developed in merely one week.
The PEME which, although a summary evaluation, did not conclusively rule out pre-existing conditions.

Petitioner’s motion for reconsideration before the NLRC was denied on May 30, 2011.

Alma Covita filed a petition for certiorari with the Court of Appeals (CA).
The CA, in its decision dated December 13, 2012 and reaffirmed by a resolution dated April 10, 2013, upheld the NLRC ruling, finding insufficient evidence to prove that Rolando’s chronic renal failure was either work-related or contracted during his employment period.
The petitioner contended that:

The working conditions on board, characterized by continuous stress and overwork, should have contributed to his high blood pressure and subsequent kidney failure.
The provision in Section 20B(4) of the Standard Employment Contract, which creates a disputable presumption that illnesses not expressly listed may still be work-related, imposes the burden on the respondents to disprove a work connection.
His previous assignments with the same respondents could indicate that the work environment contributed to or aggravated a pre-existing condition.

The POEA Standard Employment Contract—applicable to Filipino seafarers—stipulates that, for death benefits to be payable, the seafarer’s death must result from a work-related injury or illness occurring during the contract period.
Chronic renal failure, by its very nature, is a progressive deterioration of kidney function developing over a period of months to years, not within the seven days of Rolando’s service on his final contract.
The limitations of the PEME were underscored, as it is not an exploratory examination capable of detecting all pre-existing medical conditions.

Whether Rolando Covita’s chronic renal failure is considered work-related or work-aggravated under the terms of the Standard Employment Contract.
Whether the working conditions aboard the vessel (stress, heavy workload, overfatigue) contributed to the onset or aggravation of his illness.

Whether the illness manifested during the term of his employment contract, a requirement for entitlement to death benefits under Section 20 of the Standard Employment Contract.
Whether his short duration of service (approximately one week on the final assignment) can be causally connected to a chronic condition with a typically gradual onset.

Whether the petitioner’s reliance on the disputable presumption provision in Section 20B(4) effectively shifted the evidentiary burden onto the respondents.
Whether the petitioner provided sufficient, credible, and substantial evidence to prove the work-relatedness of the illness despite its chronic nature.

Whether mere allegations about stress and heavy workload are adequate to establish a causal link between Rolando’s working conditions and his chronic renal failure.
Whether the medical and factual records support the contention that the illness was incurred or aggravated during his contract with the respondents.