G.R. No. 188638 - Philippine Transmarine Carriers, Inc. vs. Cristino

Joselito Cristino, a Filipino seaman employed since 1992, worked as a fitter for Philippine Transmarine Carriers, Inc. (PTCI).
On May 30, 2006, Cristino signed a new Contract of Employment with PTCI for its principal, Northern Marine Management, to serve aboard the vessel M/V Stena Paris.
Under the nine‐month contract, Cristino was required to work at least 44 hours per week in exchange for a monthly basic salary of US$670, overtime pay of US$373, and additional benefits including vacation leave and guaranteed overtime (GOT) pay.

In October 2006, Cristino noticed a palpable mass on his leg, which he initially dismissed as a minor inflammation or benign cyst.
Persistent bouts of severe discomfort eventually led to his hospital admission in Denmark on January 29, 2007.
Diagnostic procedures (incision, CT scan, and ultrasonography) revealed that Cristino suffered from a “poorly differentiated papillary tumour” and “transitio-cellular carcinoma.”

Due to the gravity of his illness, Cristino was repatriated to the Philippines on February 7, 2007.
After arrival, he was brought to the Physicians’ Diagnostic Services Center Inc. (PDSCI) where he received initial medications and wound dressing under the care of Dr. Pedro S. De Guzman.
Lacking adequate facilities at PDSCI, he was referred to Mary Johnston Hospital for his first chemotherapy session, for which petitioners reimbursed the cost (P90,000), considering it part of his sickness allowance.
Subsequent reports, including one signed by Dr. De Guzman and Dr. Raymund Jay Sugay, diagnosed him with “carcinoma of unknown origin” and indicated that his condition was “not considered work-related” pending further evaluation.

Cristino continued treatment under Dr. Jorge G. Ignacio, a medical oncologist from the Philippine General Hospital, whose evaluation diagnosed malignant melanoma—a type of skin cancer associated with sun exposure.
Dr. Ignacio’s opinion suggested that Cristino’s working conditions, which required prolonged exposure to the sun during tasks such as cleaning, repairing, and painting on deck, could have contributed to his illness.
Based on these evaluations and the high cost of treatment, Cristino demanded disability benefits and illness allowance as provided under the POEA Standard Employment Contract for Seafarers (the Contract).

Cristino filed a complaint before the Labor Arbiter for compensation and benefits, which initially dismissed his claim based on the opinion of the petitioners’ designated physicians.
On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision on July 28, 2008, awarding permanent disability benefits (US$60,000), illness allowance (P30,600 after adjustment), and attorney’s fees.
The Court of Appeals later affirmed NLRC’s decision, finding that Cristino’s illness was work-related based on his assigned tasks and that seafarers enjoy a presumption of compensability for illnesses not expressly listed in Section 32-A of the Contract.
While the petitioners settled the financial awards during their Motion for Reconsideration, they later elevated the case, arguing several reversible errors in the assessment of work-relatedness and in the computation of benefits.

The case centered on the provisions of the 2000 POEA Standard Terms and Conditions Governing the Employment of Filipino Seafarers On Board Ocean-Going Vessels, particularly Section 20-B and Section 32.
Section 20-B outlines the employer’s liability for compensation and benefits in cases of work-related injury or illness, including continued payment of wages, coverage of medical expenses, repatriation costs, sickness allowance for up to 120 days, and provisions on disability benefits.
Although malignant melanoma is not explicitly listed among the occupational diseases in Section 32-A, the Contract provides a presumption of compensability for unlisted illnesses unless the employer produces adequate contrary evidence.

Whether the Court of Appeals erred in finding that Cristino’s malignant melanoma was work-related.

Assessment of the causal nexus between Cristino’s job duties and his illness.
Evaluation of the conflicting medical opinions—between the petitioners’ designated physicians and Cristino’s independent oncologist—in establishing work-relatedness.

Whether the Court of Appeals committed reversible error by deeming that a seafarer, incapacitated from work for more than 120 days, is automatically entitled to be declared permanently and totally disabled.

Consideration of the timeline for temporary versus permanent disability as provided in the POEA Contract.
Analysis of whether the seafarer’s inability to resume his customary duties justifies the maximum disability benefits.

Whether the award of sickness allowance and attorney’s fees under the terms of the POEA Contract was correct.

Compliance with the requirements prescribed under Section 20-B regarding the amount and duration of sickness allowance.
Justification for awarding attorney’s fees on the basis of the respondent’s protracted litigation efforts and incurred expenses.

In essence, the core issue is whether the evidentiary record supports that Cristino’s illness was work-related and, consequently, whether he (and thereafter his heirs) is entitled to the full spectrum of benefits provided under the POEA Contract.