G.R. No. 135362 - Heirs of Salas, Jr. vs. Laperal Realty Corp.

Jorge P. Rosales was employed by respondents Singa Ship Management Phils., Inc. and Singa Ship Management Pte. Ltd. under a POEA-SEC contract.
His employment details specified an 8‑month contract as a steward with a basic monthly salary, designated work hours, and other employment conditions (including overtime and leave benefits).
Prior to deployment, Rosales underwent a pre‑employment medical examination and was found “fit” for duty without any restrictions.

Rosales’ duties included cleaning rooms and cabins, making bunks, and ensuring proper waste collection and disposal.
His responsibilities also covered the maintenance and safety of cleaning equipment, ordering or replacing machinery, preventing unsanitary conditions, and assisting fellow crew members.
Specifically, he was tasked with the segregation, isolation, and disposal of biomedical waste—including syringes—which is particularly relevant to the transmission risks of bloodborne diseases.

Rosales boarded the vessel Queen Mary 2 on November 26, 2012, and performed his duties while on board.
On June 25, 2013, he began experiencing abdominal muscle and joint pains that persisted despite consultation and medication provided by the ship’s doctor.
Due to the persistence of his symptoms and the need for further work‑up (especially on his liver functions), he was repatriated to the Philippines on July 20, 2013 and reported to the company‑designated physician on July 22, 2013.

Initial evaluations considered conditions such as gastritis and esophagitis, along with a diagnosis of fatty liver.
After a series of re‑evaluations, and a confirmatory Hepatitis profiling on December 9, 2013, Rosales was diagnosed with Chronic Hepatitis C infection.
The company‑designated physician, in a letter dated February 25, 2014, opined that the fatty liver was secondary to hyperlipidemia and that Hepatitis C was acquired through non‑work–related exposures.
However, on February 26, 2016, an independent physician (Dr. Emmanuel U. Trinidad) issued similar findings but declared Rosales’ condition as work‑related.

Rosales filed a complaint against the respondents seeking permanent total disability benefits, sickness allowance, reimbursement of medical and transportation expenses, and damages.
The Labor Arbiter (LA) rendered a decision that, while dismissing the claim for permanent total disability, granted him sickness allowance for 120 days, financial assistance, and attorney’s fees based on his repatriation and illness during service.
The LA found that his work did not expose him to contracting Hepatitis C, but granted benefits based on the occurrence of his illness while on board.

The National Labor Relations Commission (NLRC) modified the LA’s decision by awarding Rosales permanent total disability benefits (valued at US$60,000), in addition to attorney’s fees, while deleting the financial assistance award.
The NLRC held that Rosales’ Hepatitis C was an occupational disease acquired during his employment, as the timeline of his symptoms and repatriation corresponded with the incubation period of the virus.
The Court of Appeals (CA) later annulled the NLRC’s decision, ruling that Rosales failed to present sufficient proof that his illness was work‑related, yet still granted financial assistance of US$5,000 based on humanitarian considerations.

In the petition for review, Rosales argued that due to the prolonged lapse (over 240 days) from his repatriation and continued suffering from multiple injuries, his illness should be considered permanently and totally disabling.
He maintained that the causal work‑connection of his illness, considering his exposure to biomedical waste in the course of his duties, was sufficiently established.
Respondents countered by alleging that no concrete instance could prove that the illness was contracted on board, given the known modes of Hepatitis C transmission.

Whether Rosales’ Chronic Hepatitis C infection and associated fatty liver are work‑related and therefore compensable under the POEA‑SEC.
Whether a reasonable connection exists between his job duties (including exposure to risks from biomedical waste) and the contraction of Hepatitis C.

Whether Rosales is entitled to full, permanent total disability benefits given that he has been suffering from his condition for more than 240 days without a conclusive medical assessment by the company‑designated physician.
Whether the failure to issue a final disability evaluation within the prescribed period automatically converts the temporary assessment into one of permanent total disability.