G.R. No. 229955 - Deocariza vs. Fleet Management Services Philippines, Inc.

Petitioner Melchor Barcenas Deocariza was initially hired in 2010 as Chief Officer by Fleet Management Services Philippines, Inc. on behalf of Modern Asia Shipping Corporation.
On June 15, 2011, he was re-hired under a six-month contract with a monthly salary of US$1,350.00 (exclusive of overtime and other benefits), covered by a Collective Bargaining Agreement (CBA).
His duties included supervising the loading and unloading of vehicles aboard the vessel M.V. Morning Carina.

Prior to deployment, petitioner underwent a pre-employment medical examination (PEME) and was declared fit for sea duty by a company-designated physician.
Petitioner boarded the vessel on July 19, 2011.
On December 3, 2011, he complained of various symptoms including bruises, rashes, a slow-healing wound, fever, sore throat, and loss of appetite.
On December 18, 2011, he was brought to Seacare Maritime Medical Center in Singapore, where his laboratory tests revealed decreased hemoglobin, white cell count, and platelet count.
At Seacare, he was labeled a “high-risk patient with mechanical heart valves” and later confined at Parkway East Hospital in the Intensive Care Unit with provisional diagnoses such as possible autoimmune disease, hypoplastic anemia, viral-induced pancytopenia, and acute leukemia.
Petitioner was medically repatriated on December 26, 2011.
Subsequently, a company-designated physician at Metropolitan Medical Center (MMC) diagnosed him with Aplastic Anemia, noting that its cause is often idiopathic but can be predisposed by exposure to benzene and its compounds.

Petitioner filed a complaint on April 16, 2013 before the National Labor Relations Commission (NLRC) for total and permanent disability benefits (US$148,500.00), along with claims for moral and exemplary damages and attorney’s fees.

In his complaint, he submitted supporting documents including a letter by Atty. German N. Pascua, Jr. asserting that his illness was to be considered an occupational disease.

Respondents argued that petitioner concealed vital health information: he allegedly failed to disclose his “mechanical heart valves” during his PEME—a fact which, they argued, disqualified him from claiming disability benefits.
The Labor Arbiter (LA), in a decision dated November 20, 2013, dismissed the complaint on grounds that petitioner was unable to establish the work-relatedness of his illness and noted that his brief exposure to benzene (despite asserted use of safety gear) was insufficient to cause such medical condition.
The NLRC, in its decision dated January 30, 2014, concurred with the LA’s finding, particularly emphasizing the purported concealment of petitioner’s pre-existing condition (mechanical heart valves), and denied his claim.
Petitioner’s move for reconsideration was denied by the NLRC in a Resolution dated February 28, 2014, leading to his appeal to the Court of Appeals (CA) via Petition for Certiorari.

The CA, in its decision dated June 3, 2016, sustained the NLRC findings confirming petitioner’s concealment and ruled that he was not entitled to disability benefits since his illness was not established as work-related.
The CA further denied his claims for moral and exemplary damages, as well as for attorney's fees.
Petitioner’s motion for reconsideration before the CA was again denied in a Resolution dated February 9, 2017, prompting the filing of the present petition for review on certiorari before the Supreme Court.

The records contained conflicting declarations regarding petitioner’s heart condition:

A foreign doctor at Seacare had noted the presence of “mechanical heart valves.”
However, subsequent examinations, including chest x-rays and 2D echocardiograms performed during routine PEME and by Dr. Melissa Co Sia at MMC, found no evidence of any heart surgery or mechanical heart valves.

Evidence indicated that petitioner’s diagnosis of Aplastic Anemia was substantial, with a bone marrow aspiration biopsy confirming the condition, and studies linking chronic exposure to benzene (through his occupational duties) to the development of such disease.
Records showed that petitioner, after repatriation on December 26, 2011, had a period of 247 days without a definitive disability assessment, exceeding the 240-day extension allowed for the determination of permanent disability.

The primary issue before the Court is whether the Court of Appeals correctly held that petitioner is not entitled to total and permanent disability benefits under the 2010 Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).

Does the alleged concealment (non-disclosure of “mechanical heart valves”) by petitioner amount to willful misrepresentation that disqualifies him from claiming disability benefits?
Is there sufficient evidence to establish that petitioner’s work-related illness (Aplastic Anemia) was contracted during the term of his employment, particularly considering his exposure to benzene during his duties?
Were the findings of the NLRC, Labor Arbiter, and the CA based on a proper assessment of evidence, or were they premature and speculative?