Title
Ranoa vs. Anglo-Eastern Crew Management Phils., Inc.
Case
G.R. No. 225756
Decision Date
Nov 28, 2019
Seafarer diagnosed with cardiovascular disease onboard; claimed permanent disability benefits. SC ruled illness work-related but limited to Grade 12 due to failure to request third doctor referral.
A

Case Digest (G.R. No. 139532)

Facts:

  • Parties and Employment
    • Victorino G. Ranoa (petitioner) was hired on March 19, 2013 by Anglo-Eastern Crew Management Phils., Inc., acting for its principal, Anglo-Eastern Crew Management (Asia) Ltd., as Master of the vessel "Genco Bay" for six months with a monthly salary of USD1,943.00.
    • Petitioner's duties included commanding the ship, transporting passengers and cargo, setting course, inspecting for safety and efficiency, coordinating signaling activities, and calculating landfall.
  • Pre-Employment Medical Examination (PEME) and Deployment
    • Before deployment, petitioner underwent routine PEME, denying history or treatment for hypertension and heart disease.
    • He was declared fit for sea duty and boarded on March 26, 2013.
  • On-Board Illness and Repatriation
    • On May 21, 2013, petitioner experienced symptoms including dizziness, chest pain, vomiting, shortness of breath, and cold sweats.
    • Blood pressure measured elevated at 170/100 mmHg; petitioner was medically repatriated on May 26, 2013.
  • Medical Findings after Repatriation
    • Company-designated doctors Karen Frances Hao-Quan and Marianne C. Sy found possible cardiac dysrhythmia, coronary artery disease, and hypertensive cardiovascular disease.
    • On October 24, 2013, a Grade 12 disability rating was issued.
    • Petitioner consulted private doctor Antonio C. Pascual on April 1, 2014, who diagnosed Stage 2 hypertension and coronary artery disease, declaring petitioner unfit for sea duties.
  • Claims and Defenses
    • Petitioner claimed entitlement to total and permanent disability benefits.
    • Private respondents contended petitioner concealed a prior diagnosis of coronary artery disease and coronary angiogram.
    • They argued that petitioner could only claim Grade 12 disability benefits as per company doctors' findings.
  • Labor Arbiter Decision
    • On October 1, 2014, Labor Arbiter Eric V. Chuanico ruled petitioner totally and permanently disabled and awarded full benefits plus damages and attorney’s fees.
    • The Labor Arbiter dismissed claims of concealment, emphasizing lack of substantiation and privileged communication rules.
    • Finding petitioner asymptomatic upon boarding, and fit at PEME, the illness was compensable.
  • NLRC Decision
    • On January 30, 2015, NLRC partly granted the appeal, deleting damages but affirming all other awards.
    • It held petitioner was not guilty of concealment; an angiogram is a procedure, not an illness.
    • It emphasized the occupational disease status of cardiovascular disease per POEA-Standard Employment Contract (SEC).
    • Permanent and total disability deemed by operation of law after 240 days out of work.
  • Court of Appeals Decision
    • On February 29, 2016, the Court of Appeals reversed NLRC, denying permanent disability benefits.
    • It found petitioner failed to prove compensability, including exposure to strain at work.
    • Company doctors testified to pre-existing cardiovascular disease.
    • Petitioner did not comply with mandatory referral to a third doctor, and his allegations of concealment were dismissed.
  • Current Petition
    • Petitioner seeks reversal of Court of Appeals decision, contending no material concealment, denial of mandatory referral to third doctor, and entitlement to permanent total disability benefits.
    • Private respondents reiterate concealment and argue non-compliance with procedures, as well as evidence that petitioner later worked as seafarer.

Issues:

  • Whether petitioner was guilty of material concealment of a previous medical condition.
  • Whether referral to a third doctor is mandatory under POEA-SEC provisions.
  • Whether petitioner is entitled to total and permanent disability benefits.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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