G.R. No. 186652 - Odchigue-Bondoc vs. Tan Tiong Bio

Respondent Almario C. San Juan was engaged by petitioners Philippine Transmarine Carriers, Inc. (PTCI), General Maritime Management LLC, and Carlos C. Salinas on various occasions.
Initially hired as Chief Cook from February 24, 1992, to May 15, 2008, and re-hired on August 26, 2009 by PTCI’s principal, General Maritime Management LLC, to serve aboard MV Genmar George T for an eight-month period.
Prior to embarkation in 2009, San Juan underwent a Pre-Employment Medical Examination (PEME) wherein he declared a history of hypertension treated with medication; he was subsequently given cardiac clearance and certified as “fit to work” by PTCI’s company-designated physicians.

While performing strenuous duties—including hard manual labor for 12 hours a day and food preparations for three consecutive days between December 24 and 26, 2009—San Juan experienced fatigue, shortness of breath, and severe headaches.
Allegedly, he collapsed several times during the voyage due to the absence of timely medications and medical attention, prompting his transfer to a medical facility in India.
A Medical Certificate issued on January 19, 2010 by his attending physician in India indicated uncontrolled high blood pressure.

San Juan signed off from the vessel on January 23, 2010 and was medically repatriated to the Philippines on February 1, 2010, after which he was referred to Metropolitan Medical Center (MMC) for further evaluation and treatment.
Company-designated physicians at MMC, notably Dr. Jaime Cayetano and Dr. Raymond L. Rosales, conducted further tests including a treadmill stress test and Cranial MRI, and subsequently certified, on April 20 and April 30, 2010 respectively, that San Juan was fit to resume sea duties despite his controlled hypertension.

On May 26, 2010, San Juan filed a complaint seeking permanent total disability benefits, sickness allowance, and other damages, contending that despite his Certificate of Fitness for Work, he was not re-hired by PTCI.
Additionally, San Juan alleged that he received only three months of sickness allowance (US$698 per month) instead of the full four months to which he was entitled.
The Labor Arbiter (LA) issued a decision on November 18, 2010 awarding San Juan US$60,000 in permanent total disability benefits, US$698 as the balance of sickness allowance, and attorney’s fees of US$6,069.80, while denying his claims for compensatory, moral, and exemplary damages.

Petitioners appealed the LA’s ruling to the National Labor Relations Commission (NLRC), arguing that San Juan’s claim lacked substantial evidence of a work-related illness and that his illness was not aggravated by his duties as Chief Cook.
On May 26, 2011, the NLRC reversed the LA’s decision, dismissing San Juan’s complaint on the ground that:

The conditions for his claim under the POEA standards were not met since his hypertension was not classified as an occupational disease; and
The company-designated physicians’ assessment, which declared him fit to work within the prescribed period, should prevail.

San Juan filed a Motion for Reconsideration, which the NLRC denied on July 15, 2011.

San Juan later pursued a Petition for Certiorari with the Court of Appeals (CA), contending that the fit-to-work certifications of the company-designated physicians were in conflict with the findings of a later second opinion by his personal physician, Dr. Antonio C. Pascual.
On December 11, 2012, the CA granted San Juan’s petition by reinstating, in modified form, the LA decision:

The permanent total disability benefits and sickness allowance awards were affirmed; however, the award for attorney’s fees was deleted for lack of sufficient factual and legal basis.
The CA emphasized a disputable presumption that San Juan’s illness was work-related, though his claim was primarily premised on contrasting medical assessments.

Petitioners filed a Motion for Reconsideration with the CA, which was denied on June 6, 2013.

Whether the CA erred in granting San Juan permanent total disability benefits in light of the fact that the company-designated physicians had declared him fit for work within the prescribed period under the POEA-SEC.
Whether the conflicting medical opinions between the company-designated physicians and San Juan’s own physician warranted a referral to a third doctor, as mandated under the applicable rules.
Whether San Juan’s claim for the balance of his sickness allowance (amounting to US$698.00) is justified given that he was declared fit to work before the full period of entitlement had elapsed.
Whether procedural and substantive errors were committed in assessing the causal connection between San Juan’s work conditions and his alleged disability.