G.R. No. 230357 - Leoncio vs. MST Marine Services , Inc.

Petitioner Almario F. Leoncio was employed by private respondent MST Marine Services (Phils.), Inc., a domestic manning agency, with private respondent Thome Ship Management Pte. Ltd. as one of its principals, for more than 18 years beginning May 5, 1996.
Over the years, Leoncio was deployed on various vessels and experienced multiple redeployments, including a demotion after being treated for his coronary artery disease/hypertensive cardiovascular disease (CAD/HCVD) in 2001.

On August 23, 2001, Leoncio disembarked from M/V Golden Stream due to a medical emergency related to his heart condition; he was repatriated and treated by a company-designated physician, after which he was declared “fit to work” and redeployed.
On January 27, 2014, he was employed as Chief Cook on board M/V Knossos under a POEA Standard Employment Contract and, having passed a pre-employment medical examination (PEME), was declared “fit for sea duty.”
While on duty on May 25, 2014, Leoncio experienced sudden heavy chest pains, shortness of breath, facial numbness, and a hypertensive reaction, symptoms that recurred in June 2014.

On June 8, 2014, following his recurring symptoms, Leoncio was admitted to Geelong Hospital in Australia where he was diagnosed with “unstable angina” and underwent Percutaneous Coronary Intervention (PCI) to address a severe lesion in his right coronary artery (RCA).
After his medical procedure, he was repatriated to the Philippines on July 12, 2014 and subsequently underwent further examination and treatment at St. Luke’s Medical Center under the care of Dr. Elpidio Nolasco.
During his treatment, MST Marine inquired about his complete medical history, and Dr. Nolasco confirmed that Leoncio had previously undergone a stenting procedure (noting stents in his Left Anterior Descending [LAD] and Left Circumflex [LCX] arteries) in 2008 or 2009.

MST Marine cut off Leoncio’s medical and sickness allowances on the ground that he failed to disclose the earlier stenting procedure during his PEME in 2014.
Relying on the fact that his coronary artery disease had been known and managed since 2001, Leoncio argued that his non-disclosure of the procedure was immaterial and that the stenting was a remedial measure.
Petitioner subsequently filed a complaint for permanent total disability benefits, contending that the new lesions (treated by PCI in 2014) were not related to his earlier stenting and thus entitling him to compensation.

The Labor Arbiter rendered a decision on April 20, 2015, in favor of Leoncio, awarding him permanent total disability benefits, sickness allowance, moral and exemplary damages, and attorney’s fees.
The National Labor Relations Commission (NLRC), in its Decision dated July 28, 2015, reversed the Labor Arbiter’s decision on the ground that Leoncio’s non-disclosure of the 2009 stenting procedure constituted fraudulent misrepresentation under the POEA-SEC.
The Court of Appeals (CA) sustained the NLRC’s decision in its November 9, 2016 ruling, and Leoncio’s subsequent motion for reconsideration was denied in the CA’s Resolution dated March 2, 2017.
Petitioner then elevated the case to the Supreme Court via a petition for review under Rule 45 of the Rules of Court.

Petitioner argued that his coronary artery disease was a pre-existing condition known to his employers since 2001, and that the stenting procedure was a remedial measure rather than a new or concealed illness.
Respondents contended that, as his employment was contractual, each PEME required full and updated disclosure of all pre-existing medical conditions, including any past treatments or procedures, thereby characterizing his non-disclosure as fraudulent misrepresentation.
The dispute centered on whether the failure to disclose the prior stenting procedure amounts to willful concealment that should disqualify him from claiming the benefits awarded by the Labor Arbiter.

Whether Leoncio’s non-disclosure of the stenting procedure during his PEME in 2014 constitutes willful concealment and/or fraudulent misrepresentation under Section 20(E) of the 2010 POEA-SEC, thus disqualifying him from permanent total disability benefits.
Whether the work-relatedness of Leoncio’s pre-existing coronary artery disease/hypertensive cardiovascular disease, which had been known to the respondents since 2001, should be negated by his alleged failure to disclose the 2009 stenting procedure.
Whether the lower tribunals (NLRC and CA) erred in their respective decisions by failing to appropriately consider the undisputed facts that could support a different conclusion in favor of the petitioner.