G.R. No. 259609 - Davantes vs. C.F. Sharp Crew Management, Inc.

Paolo B. Davantes (petitioner) worked as a seafarer with C.F. Sharp Crew Management Inc. on behalf of its principal Claus-Peter Offen Tankschiffreederei (GmbH & Co.) KG for about 20 years without prior health issues.
On May 13, 2017, Davantes was hired as an able seaman on the vessel BSL Elsa under a one-month contract governed by the Verdi/IMEC-IBF TCC Collective Bargaining Agreement (CBA).
Before deployment, Davantes underwent a Pre-Employment Medical Examination (PEME) and was declared fit to work.

On June 24, 2017, the vessel crew conducted an emergency drill under extreme heat; Davantes experienced dizziness and was allowed to rest in his cabin.
Despite feeling dazed and later suffocated, Davantes completed his duty but reported his condition only at 9:00 a.m. on June 25, 2017.
He was disembarked and treated first at a shore-side clinic in Venezuela, then hospitalized and underwent a Coronary Bypass Graft surgery.
On July 25, 2017, he was repatriated to the Philippines and referred to Dr. Robert Lim at Cardinal Santos Medical Center.
After extensive testing and treatment, Dr. Lim diagnosed him with myocardial infarction, coronary artery disease, and hypertension—declaring him unfit to work.
Dr. Antonio C. Pascual of the Philippine Heart Center also declared Davantes unfit to work.

On March 7, 2019, Davantes filed a complaint for total and permanent disability benefits, damages, and attorney's fees against C.F. Sharp.
He had earlier received USD 20,900.00 as compensation on March 14, 2018 but claimed this was grossly inadequate compared to the USD 102,308.00 he claimed under the CBA.

Davantes was referred for additional medical evaluation and given a final disability rating of Grade 7 for moderate residual disorders.
Davantes had a prior diagnosis of hypertension in 2010 and was a smoker and occasional drinker.
Davantes previously filed and dismissed a similar complaint after a settlement and executed a release of all rights on March 14, 2018.
The current suit should be barred by res judicata.
The CBA requires disability to result from an accident, which Davantes failed to prove.
Davantes deliberately concealed his pre-existing hypertension during the PEME.

Labor Arbiter (LA) ruled in favor of Davantes awarding him total and permanent disability benefits amounting to USD 77,948.00 plus attorney's fees, invalidating the prior quitclaim.
National Labor Relations Commission (NLRC) affirmed but modified the award recognizing entitlement under the POEA Standard Employment Contract (POEA-SEC) amounting to USD 60,000.00, rejecting the application of the CBA and dismissing res judicata defense.
Court of Appeals (CA) granted C.F. Sharp's petition for certiorari, annulling NLRC decisions due to Davantes's concealment of pre-existing hypertension leading to disqualification from benefits.
CA found Davantes's disability permanent by operation of law due to employer's failure to give final medical assessment but disqualified benefits due to concealment.

Davantes contested the CA ruling asserting (a) no proof of concealment and (b) entitlement to disability benefits.
Arguments centered on the validity of prior settlement, application of labor laws and POEA-SEC, and standards on concealment during PEME.

Whether or not Davantes's disability benefits claim is barred by reason of res judicata due to prior dismissal and settlement.
Whether Davantes is entitled to total and permanent disability benefits under the CBA or the POEA-SEC.
Whether Davantes knowingly concealed his pre-existing hypertension during his PEME, thereby disentitling him from claiming benefits.
Whether the quitclaim executed by Davantes is valid and enforceable.