Title
Seacrest Maritime Management, Inc. vs. Alma Q. Roderos
Case
G.R. No. 230473
Decision Date
Apr 23, 2018
Seafarer with colon cancer claimed work-related illness and benefits. Supreme Court ruled illness not occupational, no substantial evidence of work causation. Company physician final assessment upheld; petitioners prevailed.
A

Case Digest (G.R. No. 230473)

Facts:

  • Parties and Employment
    • The respondent, Alma Q. Roderos, is the widow and legal heir of Francisco Roderos, a Filipino seafarer.
    • Francisco Roderos was employed under a Contract of Employment with Heming Shipping Asia Pte. Ltd., through its Philippine manning agent, Seacrest Maritime Management, Inc.
    • Roderos served as Chief Cook aboard the vessel "MT ANNELISE THERESA" for six months, receiving a basic monthly salary of US $648 plus overtime pay and annual leave with pay.
  • Medical Incident and Diagnosis
    • In July 2011, Roderos experienced constipation and abdominal pains which persisted until September 2011.
    • While at the Port of Rostock, Germany, on September 4, 2011, he was hospitalized in Hamburg-Wilhelmsburg Hospital with symptoms including blood in stool and swollen intestines.
    • Roderos was repatriated and admitted to St. Luke's Medical Center in the Philippines on September 29, 2011.
    • He was diagnosed with stage 4 Colon Adenocarcinoma with metastasis to pericolonic lymph nodes.
    • Chemotherapy was initiated under company-designated physician Dr. Natalio Alegre, who subsequently issued a medical report declaring the illness not work-related.
  • Legal Proceedings
    • Based on the medical report and non-inclusion of colon cancer in the POEA's list of occupational diseases, chemotherapy was discontinued.
    • Roderos sought disability benefits through his union (AMOSUP) but failed to settle with the employer.
    • He filed a complaint for disability benefits, illness allowance, attorney's fees, and medical expenses before the Labor Arbiter (LA), who dismissed the case.
    • On appeal, the National Labor Relations Commission (NLRC) affirmed the dismissal.
    • Roderos died during the pendency of the appeal; his widow was substituted as complainant.
    • The Court of Appeals (CA) reversed the NLRC, ruling the illness to be work-related or, at minimum, work-aggravated due to dietary and work conditions.
    • The CA awarded the widow US$60,000 for total and permanent disability, US$6,000 for attorney's fees, and imposed six percent interest from the date of death.
    • Petitioners moved for reconsideration which the CA denied, prompting this Supreme Court appeal.

Issues:

  • Whether the illness (stage 4 Colon Adenocarcinoma) of Francisco Roderos was work-related and thus entitling the respondent to disability and death benefits under the POEA-SEC and related agreements.
  • Whether the Court of Appeals erred in awarding attorney's fees without finding bad faith or malice.
  • Whether the imposition of a six percent interest from the date of death was proper given the non-payment was based on legal grounds.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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