G.R. No. L-10520 - Tanada vs. Cuenco

Teodoro C. Razonable, Jr. was engaged in May 2014 as a Chief Engineer by Torm Shipping Philippines, Inc. on behalf of its foreign principal, Torm Singapore Pvt., Ltd.
Prior to his engagement, he underwent a Pre-Employment Medical Examination (PEME) on May 28, 2014, and was declared fit for sea duties.
His initial deployment was on a five‑month contract from July to December 2014.
On January 20, 2015, he signed another five‑month contract and boarded the vessel "Torm Almena" on January 26, 2015.

Petitioner alleged that his work as a Chief Engineer involved hard manual labor amidst strenuous conditions.

He claimed to work beyond the standard eight hours inside a 40‑degree Celsius engine room.
He alleged that he was compelled to consume unhealthy food prepared by the vessel’s kitchen staff.
He maintained that he was continuously exposed to extreme temperatures, harsh weather conditions, and both physical and emotional stress.

In May 2015, while performing his duties in the engine room, he began experiencing chest pains and tightness.

These symptoms were initially ignored.
The pain persisted, prompting him to report the issue to the ship captain toward the end of May 2015.
Due to the impending expiration of his contract, it was claimed that he was not sent for further medical evaluation abroad.

On June 4, 2015, petitioner was signed off at a convenient port in Ghana upon the expiration of his contract, and he arrived in the Philippines on June 6, 2015.
Upon repatriation, he reportedly notified the respondents and requested medical assistance for his symptoms; however, he was advised to consult his own doctor.
He then consulted Dr. Rogelio M. Martinez, who prescribed Isordil Sublingual and Celebrex.
Subsequent PEMEs:

In July 2015, a PEME conducted by a company‑designated doctor for a potential re‑deployment revealed “concentric left ventricular hypertrophy with global hypokinesia.”
Another PEME on November 14, 2015, confirmed the initial findings and added “pulmonary hypertension” and “ischemic myocardium (interventricular septum)” with stress‑induced myocardial ischemia.
A December 5, 2015 test further revealed “complete right bundle branch block and left ventricular hypertrophy.”

Due to these findings, petitioner was declared unfit for sea duties, and on April 14, 2016, an UNFIT Waiver was issued.

Petitioner claimed that his cardiovascular and renal illnesses were work-related, having developed from the strenuous working and environmental conditions aboard the vessel.
He asserted that these illnesses rendered him totally and permanently disabled, preventing him from securing subsequent employment as a Chief Engineer for over 240 days after repatriation.
He sought full disability benefits amounting to US$60,000.00, along with a 10% attorney’s fee based on the total award under the POEA‑Standard Employment Contract (SEC).

Respondents maintained that petitioner completed his contract without incident and was repatriated solely upon the contract’s expiration.
They argued that there was no record or evidence of any medical complaint on board or immediately upon arrival in the Philippines.
It was contended that petitioner’s failure to undergo the mandatory post‑employment medical examination by the company‑designated doctor forfeited his claim for disability benefits.
Respondents further asserted that his allegations were unsubstantiated and merely based on his self‑serving statements without credible supporting evidence.

The Regional Conciliation and Mediation Board (RCMB) issued a decision on November 24, 2016, declaring petitioner unfit to work and entitled to disability benefits.

The RCMB’s decision was subsequently reaffirmed by a Resolution on March 7, 2017, despite a motion for reconsideration by respondents.
On appeal, however, the Court of Appeals (CA) reversed the RCMB decision, ruling that petitioner failed to provide sufficient evidence that his diseases were work‑related or that they were contracted during his employment.
The CA denied petitioner’s motion for reconsideration in a Resolution dated August 20, 2018.

Petitioner elevated the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
He challenged the CA’s findings, arguing that mere probability should suffice to establish that his illnesses are work‑related.
The controversy centers on factual matters regarding the timing and causation of his illnesses and whether they fulfill the requirements for compensability under the POEA‑SEC.

Whether petitioner has sufficiently proven, by substantial evidence, that his cardiovascular and renal illnesses are work‑related and were acquired or aggravated during the term of his employment with respondents.

Did petitioner’s working conditions and job responsibilities contribute to the development or aggravation of his illnesses?
Is there a direct causal nexus between his service on board and the subsequent diagnosis of his illnesses?

Whether petitioner complied with the procedural requirements set forth under Section 20(A) of the 2010 POEA‑Standard Employment Contract, particularly the submission to a post‑employment medical examination by a company‑designated doctor.
Whether the evidence on record is adequate to overcome the burden of proof, given that mere allegations and general statements are insufficient to establish compensability for disability benefits.