Title
Avior Marine, Inc. vs. Turreda
Case
G.R. No. 250806
Decision Date
Sep 29, 2021
Seafarer diagnosed with work-related hypertensive cardiovascular disease; company’s incomplete medical assessment led to permanent disability benefits award.

Case Summary (G.R. No. L-8966)

Factual Background

Respondent Turreda was hired as a Chief Cook on December 16, 2015, under a nine-month contract and was declared fit for sea duties after a pre-employment medical examination. He experienced severe headaches while onboard the vessel Water Phoenix in June 2016, leading to his repatriation due to a diagnosis of migraines. After his return to the Philippines, he underwent further medical examinations, revealing more serious conditions, including hypertensive cardiovascular disease.

Medical Assessments and Certifications

Subsequent to his repatriation, Turreda was evaluated by the company-designated physician, who declared him fit to work shortly after identifying his medical issues. However, the respondent later consulted his doctor of choice, who diagnosed him with multiple health concerns and stated he was unfit for work, prompting Turreda to file a disability complaint against the petitioners.

Procedural History

The Labor Arbiter initially dismissed Turreda’s complaint, ruling that his illness was not work-related and that he was cleared by the company-designated physician. This decision was appealed to the NLRC, which overturned the Labor Arbiter's findings and awarded Turreda total and permanent disability benefits, citing insufficient medical evaluation from the company-designated physician.

Court of Appeals Ruling

The CA upheld the NLRC’s decision, concluding that the assessment by the company-designated physician was not definitive or complete. The CA noted that the documents provided lacked necessary signatures and medical evidence, which rendered Turreda's condition uncertain and led to a legal presumption of total and permanent disability.

Key Legal Issues

The primary legal issues revolved around whether Turreda's illness was work-related and if the medical assessment provided by the company-designated physician was complete and definitive. According to the POEA-SEC, illnesses sustained during employment can be compensable if they meet the criteria of being work-related.

Court's Conclusion

The Supreme Court affirmed the CA’s ruling, holding that Turreda's hypertensive cardiovascular disease was indeed work-related, as he exh

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