G.R. No. 229372 - Maryville Manila, Inc. vs. EspiNo.

Maryville Manila, Inc., acting as a local manning agency for Maryville Maritime, Inc., deployed seafarer Lloyd Espinosa.
Lloyd was employed under specific contractual arrangements to work abroad, serving on board vessels such as the M/V Renuar and, later, the M/V Iron Manolis.

From December 11, 2010, to April 23, 2011, the vessel M/V Renuar and its entire crew, including Lloyd, were held hostage by Somali pirates.
Lloyd was repatriated on May 5, 2011 following the hostage incident.

Maryville Manila rehired Lloyd on January 10, 2012 for a nine-month tour of duty on the M/V Iron Manolis.
Lloyd was again repatriated prematurely on August 29, 2012, which became the basis of the ensuing dispute regarding the reason for repatriation.

On July 15, 2013, Lloyd filed a complaint before the labor arbiter for total and permanent disability benefits.
Lloyd alleged that he suffered from a series of work-related mental health issues—including Occupational Stress Disorder, Hypomanic Mood Disorder, Bipolar Condition, a possible Schizophrenic Episode, and Post-traumatic Stress Disorder—as a result of the traumatic hostage incident.
He further claimed that Maryville Manila failed to provide him with adequate medical assistance upon his return.

The labor arbiter ruled in favor of Lloyd by awarding disability benefits (USD 60,000.00) and attorney’s fees on the ground that the employer failed to prove that Lloyd voluntarily repatriated.
Dissatisfied, both parties appealed to the National Labor Relations Commission (NLRC). The NLRC reversed the labor arbiter’s decision, dismissing Lloyd’s claim on the basis that he failed to establish that he was repatriated for medical reasons and did not comply with the mandatory reportorial requirement.
Lloyd then elevated the case to the Court of Appeals (CA) through a petition for certiorari, which on September 1, 2016, set aside the NLRC’s decision and reinstated the labor arbiter’s award, giving more credence to Lloyd’s positive assertion that he sought but was refused medical examination.
Maryville Manila subsequently moved for reconsideration of the CA’s decision, which was denied, prompting the present recourse to the Supreme Court.

Whether Lloyd was repatriated due to medical reasons or voluntarily disembarked.

The case hinges on establishing if the repatriation was necessitated by a work-related medical condition.
It involves evaluating contrasting evidence regarding the presence or absence of medical symptoms at the time of repatriation.

Whether Lloyd complied with the requirement to report to the company-designated physician within three working days after repatriation.
The significance of this reportorial obligation, and whether its noncompliance affects his claim for disability benefits.

Whether Section 20(A) (applicable during the term of contract) or Section 32-A (governing post-contract manifestations) of the POEA-SEC should govern in the context of Lloyd’s alleged work-related illnesses.
Determining if the illnesses, which manifested after his repatriation, meet the criteria for compensation under these sections.

Whether the burden of proof lies on Lloyd to demonstrate that his repatriation was for medical reasons and that his condition was causally linked to his work environment.
The adequacy and weight of the evidence presented by both parties in support of their respective positions.