G.R. No. 219872 - Mabute vs. Bright Maritime Corp.

Jaime Mabute was hired by Bright Maritime Corporation (BMC) in May 2011 for its principal, Evalend Shipping Company.
He was deployed as Chief Engineer on board MV Go Public with an initial contract term of four months, later extended for another five months (ending in February 2012).
Prior to deployment, a fit-to-work Pre-Employment Medical Examination (PEME) was conducted wherein Jaime was declared fit despite the latent nature of some medical conditions.

On November 21, 2011, while aboard the vessel, Jaime experienced noticeable stomach pain, loss of appetite, weakness, and significant weight loss, leading to difficulties in performing his duties.
In December 2011, further symptoms were observed, including yellowish discoloration of his skin, an enlarged abdomen, and dark colored urine.
He was admitted to a hospital in China for six days where tests revealed anemia, elevated liver profiles, dyslipidemia, and a hepatic mass, prompting a recommendation for immediate medical repatriation.

Jaime was repatriated and, on January 1, 2012, admitted to the University of Santo Tomas Hospital for further treatment.
Medical findings indicated that he had contracted Hepatitis B Infection since 2007, a condition for which he had not been vaccinated nor adequately monitored.
A subsequent Medical Progress Report dated January 10, 2012, by the company-designated physician, diagnosed Jaime with stage 4 Hepatocellular Carcinoma (liver cancer).
The physician opined that liver cancer, typically resulting from cirrhosis due to Hepatitis B or C, developed over time and was non-work-related per his assessment.

After being discharged on January 11, 2012, Jaime’s health continued to deteriorate, leading him to seek further consultations, including those from alternative practitioners.
Jaime ultimately died on January 18, 2012, from cardiorespiratory arrest precipitated by hepatocellular carcinoma.
Maximina T. Mabute, his wife, subsequently filed a complaint with the National Labor Relations Commission (NLRC) seeking death benefits, burial assistance, moral and exemplary damages, and attorney’s fees under the POEA-SEC.
BMC denied the claim, arguing that his death was not work-related but rather the result of a pre-existing condition (Hepatitis B infection).

The Labor Arbiter (LA) dismissed the complaint for lack of merit regarding work-related death, awarding only a nominal amount as burial benefits.
The NLRC and the Court of Appeals (CA) both upheld the LA’s finding that the death was not work-related, basing their ruling on the certificates of death and the findings of the company-designated physician.
The CA expressly noted that a fit-to-work PEME cannot be conclusive proof that the applicant was free from latent conditions and that the presumption of work-relatedness under the POEA-SEC was not sufficiently established by the petitioner’s evidence.

Maximina, unsatisfied with the decisions of the LA, NLRC, and CA, filed a Petition for Certiorari with the Supreme Court.
In her petition, she argued that the working conditions—including strenuous tasks, poor diet, exposure to toxins, and fatigue—could have aggravated Jaime’s pre-existing Hepatitis B infection, hastening the development of liver cancer.
The petitioner contended that the company’s reliance on its designated physician’s assessment was flawed, and that the employer should have conducted a more thorough medical examination given Jaime’s age and responsibilities.
Procedural issues were raised by BMC, including the timeliness and authenticity of the petition’s documentation; however, these were ultimately addressed in the Supreme Court’s deliberations.

Whether Jaime Mabute’s death, resulting from hepatocellular carcinoma aggravated by his working conditions, qualifies as work-related under the POEA-SEC.
Whether the aggravation of a pre-existing condition (Hepatitis B) through strenuous work and environmental factors can establish a causal connection sufficient to trigger the disputed benefits.

Whether the company-designated physician’s report, which characterized the illness as non-work-related, is sufficient to rebut the presumption of work-relatedness under Section 20 of the POEA-SEC.
Whether the fit-to-work status issued by the PEME is conclusive or if it fails to capture latent and evolving medical conditions.

Whether the death occurred during the term of the contract as required for compensability under the POEA-SEC, considering the implications of repatriation and termination of service.
Whether procedural defects raised by BMC could be used to bar the petitioner’s claim for death benefits and other remunerations.