G.R. No. 256611 - XXX56611, petitioner vs. People, respondent.

Respondent Aron S. Alarcon was hired in 2006 by petitioner Grace Marine Shipping Corporation for its foreign principal, Universal Marine Corporation.
He was employed as a messman aboard the vessel “M/V Sunny Napier II,” under a nine‐month employment contract which stated a monthly salary of US$403.
Prior to deployment, the respondent underwent a mandatory pre‐employment medical examination and was declared fit to work.
On January 11, 2007, he boarded the vessel and was tasked with duties including maintaining messroom sanitation, washing dishes and clothes, and general cleaning using various cleaning agents.

In his capacity as messman, the respondent was routinely exposed to cleaning chemicals such as surfactants, alkalines, phosphates, acids, complexing agents, bleaching agents, enzymes, and other strong chemical substances.
On August 6, 2007, while aboard the vessel, the respondent developed a skin condition and was seen by a physician in New Zealand who diagnosed “infected fungal dermatitis.”
Subsequent consultations on August 27, 2007 led to a diagnosis of “eczema squamosum” with a declaration of unfitness for duty, prompting his repatriation on August 29, 2007.

Following repatriation, the respondent was examined by the company-designated physician, Dr. Nicomedes G. Cruz, on August 30, 2007, and diagnosed with “nummular eczema” by the company-designated dermatopathologist, Dr. Eileen Abesamis-Cubillan.
Despite treatment, the respondent experienced recurring lesions, and on January 21, 2008, Dr. Cruz noted his condition as a Grade 12 disability with residual skin disorder, though he was again declared fit to work on January 31, 2008 with the notation of “minimal and resolving” lesions.
Additional letters and certifications by Dr. Abesamis-Cubillan and, later, an independent physician, Dr. Glenda A. Fugoso, indicated that the respondent’s condition could remain recurrent and might require lifetime treatment, ultimately leading to conflicting medical opinions regarding the extent of his disability.

The respondent filed a complaint before the National Conciliation and Mediation Board (NCMB) seeking US$60,000.00 as permanent total disability benefits, plus moral and exemplary damages and attorney’s fees.
His Position Paper asserted that the skin condition was work-related, being caused by chemicals encountered during his employment and not a preexisting condition.
Petitioners contended that the respondent’s illness was due to innate skin sensitivity and maintained that as he had been declared fit by the company-designated physicians, he was not entitled to the higher Grade 5 benefits he claimed.
The NCMB, after considering the evidence, awarded the respondent disability compensation based on Grade 5 disability and also granted his claim for attorney’s fees.

On May 22, 2009, the NCMB issued a decision awarding the respondent US$29,480.00 as disability benefit (later modified by the appellate court) and attorney’s fees, highlighting that the nature of his work exposed him to chemicals and stress that contributed to his condition.
Petitioners filed a Petition for Review with the Court of Appeals (CA) in CA-G.R. SP No. 109238 seeking to set aside the NCMB decision, arguing that the declared fitness by the company-designated physician negated work-related disability.
In its December 8, 2011 Decision, the CA upheld that disability benefits were governed by both medical findings and the contractual stipulations under the POEA Standard Employment Contract, emphasizing that the causal connection between the respondent’s work and his illness was proven.
The CA noted that despite the eventual declaration of fitness on January 31, 2008, the prolonged treatment period of 154 days (exceeding the 120-day threshold) rendered the respondent permanently and totally disabled.
The CA also sustained the award for attorney’s fees and dismissed petitioners’ subsequent motions, including the April 12, 2012 Resolution denying reconsideration.

Whether the respondent is entitled to disability benefits despite being declared fit to work by the company-designated physician.
Whether the prolonged treatment period (over 120 days) and recurring nature of the skin condition establish permanent total disability.

The relative weight to be given to the opinions of the company-designated physicians versus the independent physician’s certification in determining both fitness and disability.
Whether a declaration of fitness to work by a company-designated physician, in light of continued symptoms, should be considered null or insufficient.

Whether there is sufficient evidence to establish that the respondent’s skin condition is work-related, having resulted from exposure to toxic chemicals and stress associated with his duties.

Whether the respondent’s claim for attorney’s fees is justified under applicable provisions when he was compelled to litigate to recover his benefits.