G.R. No. 112752 - OSS Security and Allied Services, Inc. vs. National Labor Relations Commission

On January 4, 2012, Raymond F. Bernardo, then 37 years old and a seaman since 2010, was hired by Philippine Transmarine Carriers, Inc. and Furtrans Denizcilik Ticaret Ve Sanayi As as a messboy under a nine‐month Employment Contract approved by the Philippine Overseas Employment Administration (POEA).
This was his first contract with the petitioners.

On February 25, 2012, while serving his contract onboard the vessel, the respondent experienced ankle joint pain.
After self-medication failed to relieve the pain, he was taken to a portside medical facility in Morocco, where he was initially diagnosed with “Artritis gotosa” (gouty arthritis).
On May 22, 2012, he was medically repatriated and referred to the company-designated physician at Metropolitan Medical Center, who initially diagnosed his condition as gouty arthritis.

On June 29, 2012, Dr. Mylene Cruz-Balbon, the company-designated physician, issued a document explaining the diagnosis as a metabolic disorder secondary to a defect in purine metabolism and/or a high purine diet, emphasizing that the condition was not work-related.
Later, Dr. Cruz-Balbon certified the illness as “Post Infectious Arthritis: Gouty Arthritis.”
The respondent was under the care and rehabilitation therapy of the company-designated physician from May 25, 2012 to December 17, 2012.
The respondent later claimed that petitioners had discontinued his treatment before his gouty arthritis was fully resolved.

Due to the incomplete treatment and persisting symptoms, the respondent consulted Dr. Ramon Antonio Sarmiento and orthopedic specialist Dr. Renato P. Runas, with Dr. Runas opining that the respondent was “permanently unfit” to return to duty as a seafarer due to permanent disability.
Petitioners, however, contended that gouty arthritis is not a work-related condition.
An affidavit from medical specialist Dr. Vedasto Lim was presented by the petitioners, stating that gouty arthritis typically results from factors such as a high uric acid level (potentially due to diet, genetic predisposition, or under-excretion) and is not caused by seafaring duties.

On February 5, 2013, the respondent filed a case against the petitioners seeking permanent total disability benefits under the POEA Standard Employment Contract (POEA-SEC).
The Labor Arbiter, on June 13, 2013, ruled in favor of the respondent, holding that meals onboard could have contributed to or caused his condition, and awarded him US$60,000.00 along with attorney’s fees.
The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s award, finding that the petitioners had successfully disputed the presumption of compensability by the evidence (notably Dr. Lim’s certification and a list of balanced ship provisions).
Dissatisfied with the NLRC ruling, the respondent elevated his case to the Court of Appeals (CA) by filing a Petition for Certiorari.

On May 26, 2015, the CA reversed the NLRC’s decision and granted the respondent’s claim for permanent total disability benefits.
The CA reasoning emphasized the second certification by the company-designated physician, which suggested that the respondent’s post-infectious gouty arthritis was likely aggravated by a high purine diet onboard the vessel.
Petitioners subsequently filed a Petition for Review on Certiorari, contesting the CA’s decision.

Whether gouty arthritis, particularly in its classification as “Post Infectious Arthritis: Gouty Arthritis,” constitutes a work-related condition under the POEA-SEC.
Whether the respondent’s claim for permanent total disability benefits is valid given the conflicting medical opinions and evidence regarding the causation of his illness.
How the disputable presumption of compensability under Section 20(A)(4) of the POEA-SEC and the elements enumerated in Section 32-A should be applied in resolving the work connection of the respondent’s illness.