G.R. No. 238612 - Mariveles vs. Wilhelmsen-Smithbell Manning, Inc.

Petitioner Jerome I. Mariveles was employed as an Able-Bodied Seaman by Wilhelmsen-Smithbell Manning, Inc. and Wilhelmsen Ship Management, Ltd. on April 8, 2013.
His employment was governed by a POEA Contract of Employment with a basic monthly salary of US$ 689.00 for nine months.
Prior to deployment on March 19, 2013, Mariveles underwent a pre-employment medical examination; his physician’s referral slip indicated a diagnosis of Cardiac Arrhythmia (TET Impression).
Respondents ordered further tests (2D Echo with Doppler Study) and declared him fit to work on March 25, 2013, although maintenance medicines were prescribed for his condition.

In November 2013, while on board the MV "Perseverance," Mariveles experienced chest pain, dizziness, and difficulty breathing, followed by insomnia.
He reported his condition immediately, and on November 18, 2013, the ship’s captain referred him for medical evaluation at the Canadian Specialist Hospital in Dubai.
The physician there diagnosed him with multiple conditions: Coronary Artery Disease; Hyperlipidemia; Leukocytosis and Thrombocythemia; Hyperuricemia; and Hyperparathyroid Gland.
Mariveles was hospitalized from November 19 to November 28, 2013, and was repatriated to the Philippines immediately after discharge.

Upon arrival in the Philippines, respondents referred Mariveles to Marine Medical Services where Dr. Esther G. Go examined him and diagnosed a similar cluster of cardiovascular-related ailments.
On February 17, 2014, Dr. Go issued a Medical Certificate, assessing his condition as Grade 7 – moderate residual or disorder.
Subsequently, an independent physician, Dr. Leonardo Raymundo, also examined Mariveles and declared him “unfit to withstand the rigors of sea duty” via a Medical Certificate dated April 29, 2014.

Mariveles initiated grievance proceedings with the Associated Marine Officers and Seamen’s Union of the Philippines, seeking mediation of his disability claim.
The case was referred to the National Conciliation and Mediation Board (NCMB) for arbitration after settlement attempts failed.
The Arbitration Panel issued a Decision on September 23, 2014, finding Mariveles totally and permanently disabled due to his coronary artery disease, and granted disability benefits of US$ 93,154.00 plus 10% for attorney’s fees.
Respondents filed a Motion for Reconsideration on November 13, 2014, which was denied on December 9, 2014.
The case was elevated to the Court of Appeals (CA) where on November 27, 2017, the CA set aside the Arbitration Panel’s Decision and dismissed Mariveles’ complaint, ruling that his illness was not sufficiently proven to be work-related.

On April 27, 2018, Mariveles filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court challenging the CA Decision.
The issues raised involved the adequacy of evidence proving the work-relatedness of his illness and the timeliness or appropriateness of procedural filings.
Respondents argued that the petition was fact-based rather than raising questions of law and emphasized the company-designated physician’s opinion that the illness was not work-related.
Mariveles countered by citing case law that supports the compensability of work-related aggravation of an illness, emphasizing the strenuous work conditions and poor dietary provisions on board.
Precedents and relevant statutory provisions under the POEA-SEC were discussed as the basis for proving both work-relatedness and compensability.

Whether Mariveles’ coronary artery disease was work-related as defined under the POEA Standard Employment Contract (POEA-SEC).
Whether the evidence presented was sufficient to establish that the work conditions contributed to the aggravation or development of his heart disease.

Whether Mariveles satisfied the conditions laid down in Section 32-A of the 2010 POEA-SEC for an occupational disease to be compensable.
Whether the alleged work conditions, including strenuous duties and an inadequate diet, adequately connected his illness to his employment.

Whether the petition for review was properly filed within the required period under Rule 45 versus the 10-day period provided under Article 262-A/276 of the Labor Code.
Whether the CA committed grave abuse of discretion by allowing respondents to file their petition outside the prescribed period and due process in the filing of administrative remedies.

Whether the Court of Appeals erred in overruling the findings of the Arbitration Panel and dismissing Mariveles’ claim by concluding that there was no reasonable work connection.