G.R. No. 204262 - Madridejos vs. NYK-Fil Ship Management, Inc.

Mario C. Madridejos, a Filipino seafarer, was employed by NYK-FIL Ship Management, Inc. under a contract effective for 10 months.
The contract, signed on March 25, 2010, provided details on basic salary, overtime, and benefits, and was subject to a probationary period (three months) during which either party could terminate the agreement on notice.
Madridejos’ employment involved working on board the vessel “Crystal Symphony/Serenity” as a Demi Chef.

On April 28, 2010, shortly after commencing aboard the vessel on April 10, 2010, Madridejos claimed to have slipped on a metal stairway and sustained injuries to his abdomen and chest from striking a metal pipe.
He was immediately attended to by the ship’s doctor and diagnosed with a “sebaceous cyst to the right of the umbilicus.”
The following day, he received treatment at Spire Southampton Hospital in England where the cyst was excised under local anesthesia, with the wound closed using three stitches.
Despite the relatively minor nature of the operation, subsequent claims suggested a persistent condition allegedly aggravated by his working conditions.

On July 5, 2010, NYK-FIL terminated Madridejos’ employment pursuant to the contractual probationary clause, citing the provisions of the employment agreement.
A formal notice of termination was issued, and he was repatriated to the Philippines on July 6, 2010.
Madridejos contended that his contract was prematurely terminated due to his unwanted health condition and not for contractual or probationary reasons.
Following termination, he claimed that he had sought medical referral from the company-designated doctor but was denied due to the assertion that his illness was not work-related.

Madridejos asserted that his sebaceous cyst was aggravated or caused by the nature of his work as a seafarer and was, therefore, work-related and compensable as an occupational disease.
He presented various supporting documents, including a letter from Dr. Byrne (who performed the cyst excision) and subsequent medical certificates from physicians in the Philippines, which diagnosed his condition under differing disability grades.
Additionally, his pre-employment medical record indicated he was “fit to work,” which he argued proved that the cyst was incurred and aggravated during his service.

The labor arbiter initially ruled in favor of compensability by noting that the cyst was incurred during the term of employment, although he awarded only a Grade 7 disability rating due to insufficient evidence on its severity.
Both parties appealed the labor arbiter’s decision before the National Labor Relations Commission (NLRC), where the NLRC ruled that Madradejos’ claim was unsubstantiated and deemed his story “unnatural,” confirming that the repatriation was due to the expiration of his employment contract, not his medical condition.
The decision of the NLRC was further affirmed by the Court of Appeals, which dismissed Madridejos’ petition on the basis that there was no credible evidence linking his illness with his employment conditions.
Madridejos then elevated the issue to review via a Petition for Review on Certiorari, challenging the NLRC and appellate findings, and asserting that the evidentiary standard for proving work-relatedness had been satisfied.

Whether Madradejos’ sebaceous cyst, which is not enumerated among occupational diseases under Section 32 or 32-A of the POEA Standard Employment Contract, can be deemed work-related and therefore compensable.

Is there a reasonable link or correlation between the nature of his work as a seafarer and the acquisition or aggravation of his cyst?
Does the disputable presumption concerning non-enumerated diseases allow a claim for disability benefits solely based on substantial evidence presented by the claimant?

Whether Madridejos’ repatriation was due to a work-related medical condition or simply the expiration/termination of his probationary employment contract.

Was his removal from service medically induced or contractually mandated?
Does the timeline of his treatment, subsequent recovery, and continued work after the procedure support a claim of medical repatriation?

Whether Madridejos provided sufficient and credible evidence to overcome the burden imposed by the “substantial evidence” standard required to prove work-relatedness of the illness.

Did the documents and testimonies presented prove that his work environment contributed to or aggravated his condition?
Were any discrepancies in his account or the absence of certain records (e.g., accident reports, detailed ship records) fatal to his claim?

Whether the decisions of the labor arbiter, NLRC, and the Court of Appeals, which collectively found no grave abuse of discretion, should stand given the factual findings and deference to employment contracts and administrative agencies.