G.R. No. 147188 - Commissioner of Internal Revenue vs. Estate of Toda, Jr.

On July 4, 2012, respondent Dohle-Philman Manning Agency, acting on behalf of its principal, Dohle (IOM) Limited, hired Danilo L. Pacio as an Able Seaman for the vessel MV Lady Elisabeth.
Prior to his employment, on June 21, 2012, the petitioner underwent a pre-employment medical examination at Angelus Medical Clinic in Makati City.
The medical certificate issued after the examination disclosed that the petitioner had been suffering from hypertension since 2011.
Despite this pre-existing condition, he was certified fit for sea duty subject to signing an undertaking which included:

An acknowledgment that he was given proper advice and prescribed a regimen (270 capsules of amlodipine 5 mg, once a day for nine months).
A declaration that he must diligently follow the doctor’s advice or risk termination of his contract, at the agency/principal’s discretion.
An agreement that any disabling sickness arising from his hypertension would be deemed preexisting and not compensable, thereby barring any claim against the employer.

On December 10, 2012, approximately five months into employment, the petitioner complained of high blood pressure and dizziness.
He was referred to a medical facility in Romania where physicians declared him unfit for sea duties and recommended his repatriation.
Upon repatriation, the petitioner was endorsed to the company-designated physicians at the Marine Medical Services of Metropolitan Medical Center (MMC) in Sta. Cruz, Manila.
The MMC conducted thorough laboratory and diagnostic examinations—including chest X-ray, ECG, 2D Echo, Carotid Duplex Scan, Treadmill Stress Test, and plans for Cranial MRA with MRI—and concluded:

The laboratory findings showed mixed parameters (e.g., decreased hemoglobin and hematocrit, elevated uric acid, cholesterol, LDL, etc.).
The overall assessment identified hypertension and suggested a possibility of a transient ischemic attack, noting that the etiology was multifactorial and not work-related.

Despite the company’s efforts in providing a full medical evaluation and communication of the findings, the petitioner did not immediately respond.
On November 11, 2013, the respondents received a Notice of Conference from the POEA regarding a conciliation hearing based on the petitioner’s request for assistance.
During the conference, the petitioner expressed a desire to be rehired and stated that if denied, he should be compensated for his long years of service.
Subsequently, on December 16, 2013, the petitioner filed a claim for permanent total disability benefits, damages, and attorney’s fees with the Regional Arbitration Branch No. 1 of the NLRC in San Fernando, La Union.
In April 2014, the Executive Labor Arbiter rendered a decision awarding the petitioner disability benefits amounting to US$60,000 plus attorney’s fees.
The NLRC affirmed the ELA’s findings in its decision dated September 30, 2014; however, the respondents subsequently sought appeal, arguing procedural and substantive lapses.

In its Decision dated January 22, 2016, the CA reversed the NLRC’s decision.
The CA emphasized that the petitioner’s pre-existing condition had been disclosed during the PEME and ratified by the undertaking he signed.
The CA held that the petitioner failed to comply with the prescribed procedural requirements for claiming disability benefits as mandated by the Labor Code, POEA SEC, and related contractual arrangements.
The CA’s reversal underscored that while his condition (aggravated hypertension) might have progressed, the necessary protocols—especially the timeliness of follow-up evaluations—were not observed by the petitioner.

The petitioner contended that his disability (including an alleged paralysis affecting his right limbs) arose in the course of his strenuous sea duties under conditions of an undermanned crew.
He maintained that his subsequent medical evaluations, including one conducted by his private physician, confirmed his deteriorating condition, thereby entitling him to permanent total disability benefits.
Conversely, the respondents argued that:

The petitioner had fully disclosed his pre-existing hypertension and voluntarily accepted the undertaking waiving any compensability related to that condition.
The symptoms and the subsequent medical assessments clearly indicated that his condition was not work-related.
The petitioner failed to promptly report or cooperate in further medical evaluations, and thus, he did not avail himself of the remedy of a third, binding medical opinion as provided under the POEA SEC.

Whether the petitioner is entitled to permanent total disability benefits based on his claim that his hypertension and related symptoms were aggravated by work conditions.
Whether the petitioner’s prior disclosure of his pre-existing condition and his subsequent undertaking preclude his claim for disability compensation.
Whether the procedural requirements under the Labor Code and the POEA SEC for filing a disability claim were complied with by the petitioner.
Whether the CA committed an error of law in reversing the NLRC and ELA decisions awarding the petitioner disability benefits.