G.R. No. 217123 - Paringit vs. Global Gateway Crewing Services, Inc.

On June 1, 2010, Oscar M. Paringit entered into a six-month employment contract with Mid-South Ship and Crew Management, Inc., representing Seaworld Marine Services, S.A.
He was deployed as Chief Mate on the Panaman vessel Tsavliris Hellas with compensation including a basic monthly salary of US$1,700.00 for 48 hours of work, overtime pay of US$1,500.00, and vacation leave with pay amounting to US$200.00.
Before deployment, Paringit underwent a pre-employment medical examination during which he disclosed a preexisting condition—high blood pressure—but was declared fit for duty.

A few months into his assignment, Paringit began exhibiting signs of fatigue, stress, and gastrointestinal bleeding, with blood in his feces appearing on October 1, 2011.
Upon the vessel’s docking in Las Palmas, Spain, on January 13, 2012, he was rushed to the intensive care unit, underwent blood transfusion, and was diagnosed with decompensated cardiac insufficiency, severe anemia, and renal dysfunction.
After being transferred, monitored, and discharged on February 2, 2012, Paringit was medically repatriated to Manila on February 9, 2012.

Upon arrival, subsequent hospital admissions took place (e.g., at YGEIA Medical Center on February 13, 2012) where further blood transfusions and treatments were administered.
Throughout February and March 2012, multiple consultations with the company-designated physician, Dr. Maria Lourdes A. Quetulio, and specialists (including at the Philippine Heart Center) led to various diagnostic tests: repeat 2D echocardiograms and coronary angiography.
By March 5, 2012, clinical assessments indicated that Paringit was a candidate for open-heart surgery for severe valvular dysfunction, with subsequent diagnostic procedures confirming the presence of severe valvular problems.
Despite several advisories by Dr. Quetulio—including continuing medication, referrals for further evaluation, and open-heart surgery recommendations—Paringit expressed hesitance, at one point opting for herbal treatment.
On June 4, 2012, a consultation with cardiologist Dr. May S. Donato-Tan resulted in a declaration that Paringit was permanently disabled and unfit for seafaring duties, based on his cardiovascular condition.

On June 11, 2012, Paringit filed a Complaint for medical expenses and other monetary claims against Global Gateway Crewing Services, Inc.; Mid-South Ship & Crew Management, Inc.; and Captain Simeon Flores.
A quitclaim executed on June 13, 2012 revealed that Paringit had received a sickness allowance of US$6,636.70 from the vessel.
Dr. Quetulio communicated to Global Gateway on June 18, 2012 that Paringit’s heart condition was preexisting and not work-related.
After failed settlement attempts, the case proceeded to position papers: Labor Arbiter Lilia S. Savari issued an October 4, 2012 decision granting Paringit’s claim by finding his illnesses work-related or work-aggravated.
The National Labor Relations Commission (NLRC) affirmed this decision on January 31, 2013.
Respondents Global Gateway and Captain Flores then moved to the Court of Appeals, which on September 11, 2014 reversed the NLRC decision on the basis that:

Paringit opted for an alternative treatment and delayed a third-party consultation.
His Complaint was premature as it was filed during the extended 240-day treatment period.

Paringit’s subsequent motion for reconsideration was denied on February 24, 2015.
In his Petition for Review on Certiorari, Paringit assailed the reversal, contending that his heart condition was work-related and that the statutory presumption of compensability favored the seafarer.

Whether Paringit’s cardiovascular and related health problems, including congestive heart failure, hypertensive cardiovascular disease, and valvular heart disease, were caused or aggravated by the working conditions onboard the vessel.
Whether the high-fat, high-cholesterol diet and the stressful, physically taxing nature of his job contributed materially to his deteriorated health condition.

Whether Paringit complied with the mandatory procedures under Section 20-B and Section 32-A of the POEA Standard Employment Contract in claiming disability benefits.
Whether his filing of the Complaint—occurring within the prescribed period and amidst ongoing medical evaluation—was procedurally premature or improper.

Whether the respondent’s failure to act on the company-designated physician’s recommendations and to grant the requisite permission for open-heart surgery within the designated 120- or extended 240-day periods affected the claim’s validity.
Whether the alleged delay and technical barriers imposed by Global Gateway amounted to a breach of the employer’s obligations under the employment contract.

Whether the Court of Appeals erred in giving undue weight to the assessments of the company-designated physician, which contradicted the findings of Paringit’s private physician.
Whether the statutory presumption of compensability of a listed disease should have favored Paringit’s claim, putting the burden on the employer to disprove the work-relatedness of the condition.