G.R. No. 215293 - De Leon vs. Maunlad Trans, Inc.

Petitioner Lamberto M. De Leon was hired by respondent Maunlad Trans, Inc. as a Team Headwaiter for the vessel M/S Carnival Liberty.
The vessel was operated by Seachest Associates/Carnival Corporation under a POEA-approved employment contract.
Petitioner rendered services for two years, averaging ten to twelve hours of work daily.
In addition to his regular duties as Team Headwaiter, petitioner was, on certain occasions, assigned tasks as a "fire watch" during periods of vessel repair or dry-docking.

While performing as a fire watch, petitioner was exposed to extreme heat generated by welding operations.
He encountered unusual amounts of toxic fumes resulting from the mixture of alcohol and thinner with paint used after welding.
These adverse conditions were inherent to his work environment onboard the vessel, regardless of its classification as a cruise ship.

During his employment, petitioner experienced uncontrollable blinking, shaking, and difficulties in speaking and breathing, with symptoms persisting for three weeks.
He was initially referred to a neurologist in Belize where he underwent Magnetic Resonance Imaging (MRI) and CT Scan.
The diagnosis rendered in Belize was "cerebral atrophy," prompting further referral to a neurologist in Miami, Florida.
In Miami, petitioner was confined to South Miami Hospital due to the severity of his condition and was later advised to be repatriated.

Upon his return, petitioner reported to his agency and was referred to Metropolitan Medical Services, Inc.
When treatment at the initial facility failed to yield improvement, he sought further medical attention from Dr. May Donato-Tan, a specialist in internal medicine-cardiology.
Dr. Donato-Tan diagnosed petitioner with conditions described as T/C Parkinson's Disease and hypertensive atherosclerotic cardiovascular disease.
Based on this diagnosis, petitioner was declared unfit for duty in any capacity as a seaman.

Respondents acknowledged the diagnosis of Parkinson's Disease and documented several medical tests (e.g., blood count, ESR, BUN, SGPT, Creatinine, SGOT, FT4, TSH, and Serum Ceruplasmine).
The company-designated physician opined that the condition could have been secondary to genetics, immunologic factors, non-work related use of antipsychotics, or heavy metal exposure.
The designated physician stated that absent any history of heavy metal exposure on board, the condition did not appear to be work-related, leading respondents to refuse full compensability.

In a Decision dated September 26, 2011, Labor Arbiter Michelle Pagtalunan found petitioner’s claim meritorious and ordered respondents to pay disability benefits amounting to US$60,000.00 (or its Philippine Peso equivalent) plus attorney’s fees.
The Arbiter held that illnesses not specifically listed under Section 32 of the POEA Standard Employment Contract carry a disputable presumption as work-related, shifting the burden to respondents to disprove the causal connection between work conditions and the illness.
The NLRC, in its Decision dated December 15, 2012, affirmed the Labor Arbiter's ruling, holding that petitioner’s employment contributed to, if not solely caused, the development of his illness.

After the NLRC ruling was issued, respondents filed a petition under Rule 65 of the Rules of Court.
On October 9, 2013, the CA granted the petition, reversed, and set aside the NLRC decision, arguing that Parkinson’s Disease is neither listed as a disability under Sec. 32 of the POEA-SEC nor considered an occupational disease under Sec. 32-A.
The CA maintained that petitioner failed to establish a sufficient causal connection between his work and the development of the illness.
Petitioner’s motion for reconsideration was subsequently denied in the CA Resolution dated November 5, 2014.

Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court on November 26, 2014.
The petition sought to reverse the CA’s reversal and set aside the NLRC decisions, arguing that the CA committed grave errors in its findings:

Erroneously concluding that petitioner’s illness was not work-related.
Wrongfully denying the compensability of permanent total disability benefits and the award of attorney’s fees.

Petitioner contended that his illness was work-related, emphasizing the harsh exposure conditions, long working hours, stress, and fatigue inherent to his duties.
Respondents, in their Comment dated March 20, 2015, reiterated the CA’s decision.

Whether petitioner’s illness, diagnosed as T/C Parkinson’s Disease and hypertensive atherosclerotic cardiovascular disease, is compensable as a work-related injury or illness.

Did petitioner fail to establish the necessary causal connection between his work conditions and his illness?
Does the presence of a disputable presumption for illnesses not listed under Section 32 of the POEA Standard Employment Contract require the petitioner to provide additional substantial evidence?

Whether the CA erred in its finding that petitioner’s work conditions did not subject him to toxic exposure sufficient to cause or aggravate his illness.

Can the absence of similar illnesses among other employees or guests negate the contributory role of petitioner’s work environment?

Whether the award of disability benefits and attorney’s fees, as granted by the Labor Arbiter and NLRC, is justified under the POEA-SEC and applicable legal principles.

Is the evidentiary standard of "reasonable proof of work-connection" satisfied in petitioner’s case, given his exposure to harsh conditions and additional duties?