G.R. No. 241844 - Ethyl Huiso Ebal and her minor child, on behalf of the deceased Edville Cliano Beltran, vs. Thenamaris Philippines, Inc.

Edville Cliano Beltran was hired on October 9, 2015, by Thenamaris Philippines, Inc. for its foreign principal, Narcissus Enterprises S.A., to serve as Third Engineer on board the M/T Seacross.
His employment contract was for a period of seven months, and he was declared fit for sea duty through a Pre-Employment Medical Examination (PEME).
Edville’s fitness for duty was undisputed until his sudden illness while on board.

Edville boarded the vessel on October 14, 2015, and began performing his duties as Third Engineer.
On October 19, 2015, he exhibited alarming symptoms including trembling, excessive saliva, discomfort, and difficulty breathing, after having complained of sleep disturbances and erratic behavior over the preceding 48 hours.
On October 20, 2015, at 5:45 a.m., he was found not breathing; despite CPR, oxygen supply, and the administration of adrenaline, he was declared dead at 6:30 a.m.
The Medico Legal Division of the National Bureau of Investigation (NBI) initially indicated “cardio respiratory arrest” as the cause of death pending further examinations, but an autopsy later established pneumonia as the cause.

One complaint was filed by Ethyl Huiso Ebal (on behalf of her minor child, Travez Jake Ebal Beltran, representing the deceased’s interests as a legitimate heir) against Thenamaris, Narcissus, and corporate officers.
Another complaint was filed by Ju-Ann Beltran and Jhun Ville Beltran (heirs of Edville as an illegitimate child) against Thenamaris, Narcissus, and two ship captains.

The Labor Arbiter, in separate rulings, granted relief in one instance (awarding death benefits to Travez as an heir and minor child) and dismissed the complaint in another for insufficiency of evidence, thus setting the stage for higher court review.

The Labor Arbiter’s September 2, 2016 decision granted death benefits and attorney’s fees to Ethyl and Travez, finding that Edville’s work conditions, including the lack of immediate medical attention while at sea, likely triggered or aggravated his pneumonia.
A subsequent ruling by another Labor Arbiter in a different related case dismissed the claim for death benefits for insufficiency of evidence.

Further rulings by the NLRC and later the Court of Appeals (CA) produced conflicting outcomes:

The NLRC reversed the favorable Labor Arbiter decision in one case (G.R. No. 241844), dismissing the claim on the basis that work conditions were not proven to be related to the death.
In another case (G.R. No. 257584), the NLRC vacated a prior dismissal, finding the death work-related, and awarded death benefits based on the disputed presumption that pneumonia—though not explicitly listed as an occupational disease—was caused or aggravated by the working conditions aboard the vessel.

Multiple petitions and motions for reconsideration at both the CA and the NLRC level ensued, addressing issues such as venue consolidation and the adequacy of evidence to support work-related causation.

Due to the commonalities in facts and issues—specifically whether Edville’s pneumonia was work-related—the cases G.R. Nos. 241844 and 257584 were consolidated.
The petitions involved varied arguments:

Ethyl and Travez argued that Edville’s clear PEME clearance and the immediate onset of symptoms after boarding established the causal connection between his work and contraction of pneumonia.
Thenamaris and its allied respondents contended that the brief duration of exposure on board was insufficient to cause pneumonia and questioned the evidentiary basis for a work-related claim.

The final pleading before the Court addressed the substantial evidence regarding the work-relatedness of Edville’s pneumonia and the applicability of statutory benefits under the POEA-SEC.

Whether there is substantial evidence to prove that pneumonia, the cause of Edville’s death, was work-related.

Does the medical and factual evidence support that Edville’s symptoms and death were triggered or aggravated by his working conditions?
Was the absence of pneumonia symptoms during the PEME a determinative factor, or does the onset of symptoms on board establish causation?

Whether the disputable presumption of work-relatedness under Section 20(A)(4) of the 2010 POEA-SEC applies in this case.

Can Edville’s pneumonia be presumed work-related despite not being expressly enumerated as an occupational disease under Section 32-A of the POEA-SEC?
Does the burden shift to the employer to disprove the work-related nature of the disease?

Whether the death occurred during the term of the employment contract to entitle the beneficiaries to the statutory death benefits.

Is the fact that Edville died within six days of boarding the vessel sufficient to establish that the death occurred within the contract period?
How do these findings affect the calculation and distribution of death benefits among his heirs?

How the conflicting rulings of the NLRC and the CA are to be reconciled in light of the evidentiary standards provided by the POEA-SEC and the Revised Rules on Evidence.