Title
Salas vs. Transmed Manila Corp.
Case
G.R. No. 247221
Decision Date
Jun 15, 2020
Seafarer Salas, diagnosed with diabetes and gouty arthritis, deemed permanently disabled after company physician failed to issue final assessment within 120/240 days.

Case Digest (G.R. No. 247221)
Expanded Legal Reasoning Model

Facts:

  • Employment and Service Background
    • On March 6, 2014, Salas was hired as Second Officer by Transmed Manila Corporation (TMC) for its principal, Transmed Shipping Ltd. (TSL), to serve on board the vessel M/V Coalmax for an initial eight‑month contract.
    • After undergoing the required pre‑employment medical examination (PEME) and being declared fit for duty by the company‑designated physician, Salas boarded the vessel on April 4, 2014, commencing his tour of duty.
    • Upon the expiration of his contract on February 9, 2015, the parties agreed to extend his employment for another two months under the same terms and conditions.
  • Onset of Medical Issues and Initial Diagnosis
    • In February 2015, Salas experienced a series of symptoms including generalized weakness, easy fatigability, loss of appetite, and difficulty sleeping.
    • He was admitted to a hospital in Rio de Janeiro, Brazil, where he was diagnosed with diabetes mellitus and gouty arthritis (affecting both knees), ultimately being declared unfit for work and repatriated on March 21, 2015, for further evaluation and management.
  • Post‑Repatriation Medical Assessments and Discrepancies
    • Upon arrival in Manila, Salas was admitted at Marine Medical Services and referred to a company‑designated physician.
      • He was evaluated by orthopedic surgeon Dr. Ferdinand Bernal who opined that his joint pains were due to gouty arthritis and not work‑related, attributing the condition mainly to high purine intake and hereditary factors.
    • On March 23, 2015, the company‑designated physician, Dr. Margarita Justine O. Bondoc, issued a private and confidential Medical Report stating:
      • Diabetes mellitus was “usually familial/hereditary.”
      • Gouty arthritis was characterized as a metabolic disorder secondary to a defect in purine metabolism and/or high purine diet, and thus not work‑related.
    • A subsequent Medical Report dated May 4, 2015 noted normal range of motion on both knees and “cleared orthopedic wise,” yet required Salas to undergo further follow‑up laboratory examinations and re‑evaluation on May 18, 2015.
    • No further records indicated whether the repeat examinations or follow‑up assessments were actually conducted, leaving Salas’ final medical status unresolved.
  • Independent Medical Opinion and Subsequent Developments
    • Salas contended that, despite his ongoing bilateral knee pain, his medical treatment was abruptly discontinued and his request for further medical assistance was denied.
    • Consequently, he sought an independent evaluation by Dr. Victor Gerardo E. Pundavela, who on July 23, 2015 issued a Medical Certificate diagnosing him with “Degenerative Osteoarthritis with Gouty Arthritis, bilateral knee; NTDDM controlled.”
      • Dr. Pundavela highlighted that repeated stresses and strains in his work, such as prolonged standing and faulty posture, could have contributed to the aggravation of his knee condition.
      • He further found that the chronic knee pain had significantly decreased Salas’ activity tolerance to an extent that rendered him unfit to work as a seafarer.
  • Administrative Proceedings and Rulings
    • Salas filed a complaint for disability benefits, moral and exemplary damages, and attorney’s fees against TMC, TSL, and Egbert M. Ellema before the NLRC (docketed as NLRC NCR Case No. (M) 11‑13007‑15).
      • Respondents argued that Salas was not entitled to disability benefits because:
        • The company‑designated physician had declared his diabetes mellitus as not work‑related.
ii. His gouty arthritis was not work‑related and was in fact a pre‑existing condition.
  • The Labor Arbiter (LA) in its Decision dated June 28, 2016, ruled in favor of Salas, awarding him:
    • US$60,000.00 representing total and permanent disability benefits,
    • Ten percent (10%) attorney’s fees.
    • The LA emphasized that Salas had sufficiently established a causal connection between his work as Second Officer and the aggravation of his illnesses, noting the lack of contrary evidence.
  • On appeal, the NLRC reversed the LA’s decision in its Decision dated November 29, 2016, holding that Salas failed to prove his illnesses were work‑related.
    • This ruling gave little credit to Dr. Pundavela’s diagnosis, dismissing his statements as mere conjecture.
    • The NLRC maintained that the seafarer bore the burden to provide substantial evidence of causation, which Salas did not achieve.
  • Despite Salas filing a motion for reconsideration (which was denied on January 31, 2017), the case was elevated to the Court of Appeals (CA).
    • The CA Decision dated February 18, 2019 affirmed the NLRC ruling, finding no reversible error.
    • Further, a motion for reconsideration by Salas was denied in the CA Resolution dated May 14, 2019.
  • Central Facts on Medical Reporting and Final Assessment
    • The May 4, 2015 Medical Report, issued by the company‑designated physician, was not a final and definite assessment since it merely remarked upon orthopedic clearance yet mandated further examination.
    • The failure of the company‑designated physician to definitively assess Salas’ fitness to resume work played a crucial role in determining his entitlement to total and permanent disability benefits.

Issues:

  • Causal Relationship Between Work and Illness
    • Whether Salas’ diabetes mellitus and gouty arthritis were work‑related or were aggravated by his work conditions on board the vessel.
    • Whether the medical evidence sufficiently established that the illnesses were acquired or exacerbated during the term of his employment.
  • Adequacy of the Company‑Designated Physician’s Assessment
    • Whether the company‑designated physician’s failure to issue a final and definite disability assessment within the prescribed 120/240‑day period renders Salas’ condition as total and permanent by operation of law.
    • Whether the lack of detailed evaluation in the company‑designated medical reports undermined the employer’s assertion that the illnesses were not work‑related.
  • Burden of Proof and Legal Presumption
    • Whether the legal presumption in favor of the seafarer—regarding work‑relatedness of his illness under the POEA‑SEC—places the burden on the employer to disprove such connection.
    • How the contradictory statements from the company‑designated physician and the independent physician impact the overall burden of proof.
  • Applicability of the 2010 POEA‑SEC Provisions
    • Whether the provisions under Section 20 (A) concerning compensation for injury or illness, and Section 32‑A regarding the list of work‑related illnesses, were correctly applied by the CA and NLRC in dismissing the claim.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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