G.R. No. 225995 - Ventura, Jr. vs. Crewtech Shipmanagement Philippines, Inc.

Petitioner, Teodoro V. Ventura, Jr., was employed by Crewtech Shipmanagement Philippines, Inc. as Chief Cook for its principal, Rizzo-Bottiglieri-De Carlini Armatori S.P.A.
He served under a nine-month employment contract signed on October 18, 2013, with a basic monthly salary of US$710.00 plus overtime and other benefits.
Prior to boarding the vessel MV Maria Cristina Rizzo on October 31, 2013, petitioner underwent a pre-employment medical examination (PEME) and was declared fit for sea duty by the company-designated physician.

Though the petitioner claimed consistent employment for three years across different vessels, a change in vessel assignment occurred on April 4, 2014, when the vessel was transferred to Elburg Shipmanagement Phils., Inc.
In April 2014, while on board, petitioner experienced difficulty urinating accompanied by lower abdominal pain.
Upon arrival at the port of Singapore on April 30, 2014, he was examined by a specialist at the Maritime Medical Centre and diagnosed with “prostatitis” and declared “unfit for duty.”
It was noted that petitioner had a prior history of prostatitis occurring three years earlier and had been treated for a kidney stone in August 2013.

After being medically repatriated on May 1, 2014, petitioner was evaluated by a company-designated physician through further diagnostic tests including an ultrasound and a CT stonogram.
The examinations revealed the conditions:

“Cystitis with Cystolithiases”
“Prostate Gland Enlargement, Grade III with Concretions”
“Bilateral Renal Cortical Cysts” and findings consistent with benign prostatic hyperplasia (BPH).

While the treating physician maintained that these conditions were not work-related—citing genetic predisposition, dietary factors, and hormonal changes—the petitioner was continuously monitored and recommended for multiple treatment sessions including:

Extracorporeal Shockwave Lithotripsy (three sessions)
Open Prostatectomy with possible Transurethral Resection of the Prostate
Open Cystolithotripsy with possible laser intracorporeal lithotripsy and endoscopic extraction of bladder stones
Subsequent procedures including cystoscopy and bladder irrigation due to persistent symptoms.

Persisting complaints, including intermittent hypogastric pain and difficulty in removing the indwelling Foley catheter, led petitioner to seek a second opinion from independent physician Dr. May S. Donato-Tan.
In a Medical Certificate dated October 20, 2014, Dr. Tan declared petitioner permanently disabled due to the complications from his indwelling catheter and resultant frequent urinary tract infections.
Based on his condition, petitioner filed a complaint before the NLRC seeking:

The Labor Arbiter (LA) issued a Decision on April 30, 2015, dismissing the claim for disability benefits on the ground that petitioner failed to prove a work-related causal nexus, while ordering payment of sickness allowance and attorney’s fees.
The NLRC, in its Decision dated June 30, 2015, partly ruled in favor of petitioner by awarding total and permanent disability benefits amounting to US$60,000.00, alongside sustaining the sickness allowance and attorney’s fees, determining there was no fraudulent concealment by petitioner.
The Court of Appeals (CA) later reversed the NLRC award for disability benefits in its Decision dated March 1, 2016, holding that petitioner’s illnesses were not work-related, though it sustained the award for sickness allowance and attorney’s fees.
A motion for reconsideration was filed and subsequently denied on July 4, 2016, prompting petitioner to elevate the matter to the Supreme Court through a petition for review on certiorari.

Whether the Court of Appeals erred in holding that the NLRC gravely abused its discretion in awarding total and permanent disability benefits to petitioner.
Whether petitioner’s failure to disclose his previous history of prostatitis in his 2013 PEME constituted willful concealment or fraudulent misrepresentation.
Whether petitioner established a proper legal and factual basis showing a causal relationship between his work conditions (as Chief Cook) and the development or aggravation of his illnesses (Cystitis with Cystolithiases and BPH).