G.R. No. L-36941 - People vs. Saylan

Respondent Wilfredo T. de Leon was employed by petitioner Scanmar Maritime Services, Inc. as a seafarer.
His deployment was aboard vessels managed by Crown Shipmanagement Inc., the principal of Scanmar.
De Leon had rendered 22 years of service with no record of any illness during his employment until his later claim.

On November 17, 2005, before his next deployment, De Leon reported to Scanmar’s office for a pre-employment medical examination.
The company physician noticed that he dragged his right leg and referred him to a neurologist for further consultation and clearance.
His Medical Examination Certificate was then marked as “pending,” and no further follow-up or clarification occurred from the employer’s side.

Two years later, in December 2007, De Leon sent a letter to Scanmar requesting disability benefits amounting to USD60,000.
After receiving no response, he filed a complaint with the Labor Arbiter (LA) for disability benefits and attorney’s fees.
Prior to his deployment on board M/V Thuleland as a Third Mate, De Leon claimed that he experienced early warning signs of his illness, including lower abdominal pain and the appearance of blood in his stool.
He further provided several pieces of documentary evidence:

An Electrodiagnostic Laboratory Report (dated October 5, 2005) indicating chronic right L5-S1 radiculopathies in acute exacerbation.
A Medical Certification (dated November 21, 2005) from Dr. Angel Luna stating that he was unfit for work and suggesting a work-related etiology.
A Magnetic Resonance Imaging (MRI) of the lumbosacral spine (dated December 7, 2005) identifying a mild central canal stenosis at L5-S1 due to a small posterocentral disc protrusion.
A subsequent Medical Certification (dated October 6, 2006) from Dr. Ricardo Guevara indicating his unfitness for sea service.

Petitioners (Scanmar Maritime Services, Inc., Crown Shipmanagement Inc., and Victorio Q. Esta) contested De Leon’s claims and raised three primary contentions:

They refuted the claim that the illness was experienced aboard M/V Thuleland, noting no corresponding entry in the vessel’s logbook.
They argued that De Leon failed to comply with the mandatory requirement to submit to a post-employment medical examination within three days of disembarkation, as mandated by his POEA Contract.
They pointed out that he neglected to address the “pending” status on his medical certificate and did not follow the company physician’s advice to consult a neurologist.

The Labor Arbiter ruled in favor of De Leon by awarding him the USD60,000 disability benefits and attorney’s fees.
The decision of the Labor Arbiter was subsequently affirmed in its entirety by both the National Labor Relations Commission (NLRC) and the Court of Appeals (CA).
Petitioners then sought certiorari before the Supreme Court, challenging:

The awarding of benefits absent conclusive proof that the illness was contracted during the term of employment.
De Leon’s non-compliance with the three-day post-employment medical examination requirement.
The grant of attorney’s fees based on alleged bad faith of the petitioners.

Compliance with the Mandatory Post-Employment Medical Examination Requirement

Whether De Leon’s failure to submit to a post-employment medical examination within three working days from disembarkation – as required by the POEA Contract – disqualifies him from claiming disability benefits.

Whether sufficient and substantial evidence was presented to prove that the alleged L5-S1 radiculopathy was contracted during the term of De Leon’s 22-year employment.
Whether the temporal proximity of the medical evidence (dated after disembarkation) is adequate to establish a work-related causal connection.

Whether the imposition of attorney’s fees against the petitioners was justified given the circumstances and evidence presented.

Whether the labor tribunals properly assessed the credibility and probative value of the medical and circumstantial evidence.
Whether reliance on generalized employment duration, without detailed linkage to specific work-related physical stresses, suffices to establish work-relatedness of the injury.