G.R. No. 206505 - Villanueva Sr. vs. Baliwag Navigation, Inc.

Petitioner Jereme G. Villanueva, Sr. filed a complaint for permanent total disability benefits, medical reimbursement, sickness allowance, damages, and attorney’s fees against respondents Baliwag Navigation, Inc., its President Victoria Vda. de Tengco, and its principal Unitra Maritime Co., Ltd.
The petition for review on certiorari was filed under Rule 45 of the Rules of Court, assailing the decisions of the Court of Appeals (CA) and the National Labor Relations Commission (NLRC).

On May 13, 2003, Villanueva entered into a ten-month employment contract as a bosun on the vessel M/S Forestal Gaia.
A pre-employment medical examination (PEME) conducted on July 28, 2003 declared him fit for work, notwithstanding a report indicating a pre-existing heart disease.
He boarded the vessel on August 17, 2003.

While on board, Villanueva experienced a sudden onset of chest pain and difficulty breathing; he requested medical assistance but was provided only with oral medication.
His repatriation occurred on June 24, 2004 upon the expiration of his contract, not on medical grounds.
After his repatriation, Villanueva reported to the agency and requested a medical check-up. Despite several follow-ups, he was only referred to Centerpoint Medical Services.
Centerpoint established his medical history of a heart disease, subsequently declaring him unfit for work and assigning a Grade 1 disability rating.

Based on the internist-cardiologist’s confirmation of his condition, Villanueva filed a formal claim for disability benefits against the respondents.
Respondents denied liability, contending that his repatriation was due to the completion of his contract and that his current ailment, contracted outside his employment period, is not compensable.
In a Decision dated June 30, 2006, Labor Arbiter Antonio Macam dismissed Villanueva’s complaint for lack of merit, holding that the heart ailment was not compensable as it was not work-related.
The NLRC, in its Decision dated March 26, 2008, affirmed in toto the Labor Arbiter’s ruling; subsequent motions for reconsideration were denied.
Villanueva then elevated the issue to the CA through a Rule 65 petition for certiorari focusing on alleged grave abuse of discretion by the NLRC. The CA also denied the petition and his subsequent motion for reconsideration, sustaining the NLRC’s determinations.

He failed to present evidence of work connection for his heart condition, although he argued that he was no longer fit for sea duties as early as July 28, 2003, yet was deployed because of the respondents’ urgent need for his services.
His repatriation on account of a finished contract does not negate the claim for disability benefits if his heart ailment was aggravated during employment.
His claim that he complied with the mandatory post-employment medical check-up requirements was supported by his testimony that he reported to the agency for the examination and was refused, despite the contractual requirement.

Whether Villanueva’s heart ailment, which was pre-existing and known at the time of his employment, can be considered compensable as an occupational disease under the 2000 POEA-Standard Employment Contract.
Whether there is sufficient evidence that his heart disease was aggravated by the strain of his work as required by Section 32-A(11) of the same contract.

Whether his repatriation was effected due to the completion of his contract rather than on medical grounds, thus affecting the compensability of his claim.
Whether Villanueva failed to comply with the mandatory three-day post-employment medical examination stipulated in Section 20(B)(3) of the 2000 POEA-Standard Employment Contract.

Whether Villanueva met the evidentiary burden in proving that the acute exacerbation of his heart disease was directly precipitated by the unusual strain brought about by the nature of his work on board the vessel.