Title
Barko International, Inc. vs. Alcayno
Case
G.R. No. 188190
Decision Date
Apr 21, 2014
Seafarer diagnosed with work-related tuberculous adenitis and diabetes; unable to work for over 120 days, deemed permanently disabled; awarded benefits, medical expenses, and attorney’s fees.

Case Summary (G.R. No. 188190)

Facts of the Case

The respondent was hired as an Able-bodied Seaman on November 18, 2005, with a contract period of nine months. He boarded the vessel M/V Cape Iris on December 1, 2005. After experiencing health issues, including a stiff neck and swelling of the right jaw after one month onboard, he was discharged at the Suez Canal on February 2, 2006. Medical examinations indicated severe infections and complications, leading to his repatriation to the Philippines where he was diagnosed with uncontrolled diabetes mellitus and cervical tuberculosis adenitis.

Initial Claims and Denial

On July 6, 2006, the respondent filed a complaint for disability benefits against the petitioners, asserting that his illness was contracted during his employment on the M/V Cape Iris. The petitioners denied the claims, providing a contrary medical evaluation that found the respondent fit for work, leading to the NLRC's dismissal of the complaint for lack of merit.

Decision of the Labor Arbiter

The Labor Arbiter ruled in favor of the respondent on April 10, 2007, stating that his illness was contracted during his employment. This decision was based on the fact that he was unable to return to work for more than 120 days, thereby qualifying for permanent total disability benefits and medical expenses.

Resolution of the NLRC

The NLRC reversed the Labor Arbiter's decision on November 29, 2007, arguing that the illnesses in question could not reasonably be developed in a short duration and criticizing the lack of additional medical opinions. The NLRC questioned the causal connection between the respondent's employment and his medical condition.

Court of Appeals Decision

The respondent subsequently sought relief from the CA, which granted his petition on December 5, 2008, reinstating the Labor Arbiter's decision. The CA ruled that an incapacity to work for over 120 days constituted a permanent disability. Furthermore, it stated that the employment conditions could have contributed to the respondent's illnesses, thereby supporting his claim for compensation.

Motion for Reconsideration and CA's Final Ruling

The petitioners filed a motion for reconsideration, asserting that the respondent was declared fit to work before the maximum 240-day period expired, thus denying entitlement to benefits. The CA denied the reconsideration on June 3, 2009, emphasizing that earlier juris

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