Facts:

The case involves HFS Philippines, Inc., Ruben T. Del Rosario, and IUM Shipmanagement AS as petitioners against Ronaldo R. Pilar, the respondent. The events leading to the case began on October 4, 2001, when Pilar was engaged as a crew member on the Norwegian vessel M/V Hual Triumph under a nine-month contract. His employment terms included a basic monthly salary of US $981, overtime pay, and vacation leave. Pilar boarded the vessel on October 27, 2001. However, by March 2002, he began experiencing severe health issues, including loss of appetite, nausea, vomiting, and nervousness. Despite receiving medical treatment, his condition worsened, leading to his hospitalization at Komatsu Hospital in Nagoya, Japan, where he was diagnosed with depression and a gastric ulcer. The attending physician deemed him unfit for work and recommended repatriation, which occurred on April 3, 2002.

Upon returning to Manila, Pilar was examined by a physician designated by HFS, Dr. Nicomedes G. ...

Facts:

Employment Contract and Onboarding

• On October 4, 2001, respondent Ronaldo R. Pilar was hired by petitioners IUM Shipmanagement AS and its Philippine manning agent, HFS Philippines, Inc., as an electrician on the Norwegian vessel M/V Hual Triumph. The contract stipulated a 9-month duration, a basic monthly salary of US $981, overtime pay of US $646 per month, and 8 days of vacation leave with pay per month. Respondent boarded the vessel on October 27, 2001.

Onset of Illness

• In March 2002, approximately four months after boarding, respondent began experiencing symptoms such as loss of appetite, nausea, vomiting, and severe nervousness. Despite medical treatment onboard, his condition did not improve.

Medical Diagnosis and Repatriation

• On April 3, 2002, when the vessel reached Nagoya, Japan, respondent was brought to Komatsu Hospital, where he was diagnosed with depression and gastric ulcer. The attending physician declared him unfit for work and recommended hospitalization and repatriation. Respondent returned to Manila on the same day.

Post-Repatriation Medical Treatment

• Upon arrival in Manila, respondent was taken to the Medical Center Manila by an HFS representative. Dr. Nicomedes G. Cruz, a company-designated physician, confirmed that respondent was suffering from major depression and placed him under continuous medical treatment for several months. On September 19, 2003, Dr. Cruz declared respondent fit to work.

Independent Medical Opinions

• Respondent sought additional medical opinions from other physicians:
  • Dr. Anselmo T. Tronco of the Philippine General Hospital and Dr. Raymond Jude L. Changco of Mary Chiles Hospital both opined that respondent continued to suffer from major depression.
  • Dr. Arlito C. Veneracion of Mary Chiles Hospital diagnosed respondent with cholecystolithiasis, mild fatty liver, and chronic gastritis, declaring him unfit to work.

Filing of Complaint

• On November 27, 2002, respondent filed a complaint with the National Labor Relations Commission (NLRC) for underpayment of disability and medical benefits, as well as moral and exemplary damages. The NLRC referred the case to the National Conciliation and Mediation Board (NCMB) on May 6, 2003.

Respondent’s Claims

• Respondent claimed that he was entitled to disability compensation under Article 12 of the Collective Bargaining Agreement (CBA) between AMOSUP and the Norwegian Shipowner’s Association. He alleged that his depression was triggered by an incident on March 9, 2002, when he was hit on the head by an officer while sleeping, causing severe trauma.

Petitioners’ Defense

• Petitioners argued that respondent’s depression and gastric ulcer were not caused by an accident and, therefore, he was not entitled to disability benefits under Article 12 of the CBA. Instead, they claimed he was only entitled to 120 days of sick pay under Article 10 of the CBA.

NCMB Decision

• The NCMB ruled in favor of respondent, awarding him US $90,000 in disability benefits and attorney’s fees, holding that his psychological condition was compensable as it arose out of his employment.

Court of Appeals Decision

• The CA partially reversed the NCMB, ruling that Article 12 of the CBA did not apply since respondent’s illnesses were not caused by an accident or marine peril. However, the CA awarded disability benefits under Section 32 of the POEA Standard Employment Contract.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. CBA Interpretation: Article 12 of the CBA applies only to injuries resulting from accidents, marine perils, or travel-related incidents. Since respondent’s illnesses were not caused by any of these, he was not entitled to disability compensation under the CBA.
2. POEA Standard Employment Contract: Section 20(B) of the POEA contract provides that a seafarer is entitled to disability benefits if he contracts an illness or suffers an injury during employment that results in total or partial disability. The Court found that respondent’s illnesses were work-related and resulted in partial disability.
3. Conflict in Medical Opinions: The Court resolved the conflict between the company-designated physician’s opinion (declaring respondent fit to work) and the independent physicians’ opinions (declaring him unfit) in favor of the laborer, consistent with the principle of social justice.
4. Social Justice Principle: The Court emphasized that labor laws and contracts must be interpreted in favor of the worker, especially when evidence is susceptible to divergent interpretations.

Conclusion:

The Supreme Court upheld the CA’s decision, ruling that respondent was entitled to disability benefits under the POEA Standard Employment Contract but not under the CBA. The petition was denied, and costs were imposed on petitioners.