Title
Bright Maritime Corp. vs. Racela
Case
G.R. No. 239390
Decision Date
Jun 3, 2019
A seafarer claimed disability benefits for aortic valve stenosis, alleging work-relatedness. The Supreme Court ruled against him, finding no substantial evidence linking his illness to his employment as a fitter, emphasizing the need for proof of work-relatedness under POEA-SEC.
employer
ship owner
lack of evidence

Case Summary (G.R. No. 239390)

Factual Background

Respondent was hired on March 21, 2013 after a pre-employment medical examination (PEME) where he was declared “Fit for Sea Duty as Engine Rating.” He departed the Philippines on June 8, 2013 and boarded the vessel in Singapore. In February 2014, respondent began experiencing chest pains and difficulty in breathing. On March 23, 2014, he was admitted at Alisha Hospital in Israel for pulmonary edema and was diagnosed with “severe aortic regurgitation and aneurysm of the sinuses of valsava aortic root.” He underwent open-heart surgery (aortic valve replacement) on March 25, 2014, received post-operative restrictions against physical exertion for six months, and was repatriated on April 19, 2014 for medical reasons.

Upon arrival in the Philippines, respondent underwent post-employment medical examination and was immediately confined at Chinese General Hospital after referral to the company-designated physician at Alegre Medical Clinic. He was discharged on April 22, 2014 with advice to continue medical therapy. During follow-up, he complained of pain over the surgical site and a clicking sound; he was diagnosed as having “aortic valve stenosis” and referred to a cardiologist. On May 2, 2014, a cardiologist advised retrieving angiogram results and undergoing repeat 2D echocardiography in three to four months while continuing medications. After re-evaluations, the company-designated physician rendered an opinion on July 21, 2014 that because respondent’s condition was pre-existing or hereditary, no disability grading was given under the POEA-SEC, and maximum medical cure had been reached. Another medical report dated July 23, 2014 reiterated that no disability grade was assigned because the condition was deemed not work-related.

Respondent continued treatment under the company-designated physician until August 27, 2014, when he was discharged. A coronary angiography was performed on August 26, 2014, with the cost shouldered by petitioners. On September 25, 2014, respondent consulted Dr. Efren R. Vicaldo, who issued a medical certificate diagnosing valvular heart disease with severe aortic regurgitation and aneurysm of sinus valsalva, status post aortic valve replacement, normal coronary arteries, and a dilated left ventricle with systolic dysfunction. Dr. Vicaldo assigned an impediment grade of VI (50%) and declared respondent unfit for sea duty.

Respondent filed a disability complaint on June 9, 2015. He claimed he was not informed of the medical assessment of the company-designated physician and alleged that petitioners avoided referral requests to a third doctor. He prayed for full disability benefits (US$60,000.00), moral and exemplary damages, and attorney’s fees. Petitioners denied liability and maintained that respondent had been informed of the company-designated physician’s assessment during a meeting with claims officers assigned to coordinate respondent’s case, that respondent understood his ailment was not work-related, and that petitioners would pay medical expenses until the 120th day or up to August 27, 2014, when treatment would end. Petitioners further emphasized that respondent did not protest the assessment, only requested reimbursement/shouldering of the coronary angiogram, which was granted. They also asserted that the subsequent attempt to comply with the Third-Physician Rule was obstructed by respondent’s counsel through premature filing and communications inconsistent with genuine compliance.

Labor Arbiter Proceedings

In the decision dated April 19, 2016, Labor Arbiter Thomas T. Que, Jr. ruled that respondent had acted within his rights despite failure to obtain the opinion of a third doctor, reasoning that the employment contract and CBA provisions on the procedure were permissive rather than mandatory, given the use of “may.” On the medical issue, the Labor Arbiter held that petitioners had impliedly admitted work-related liability by providing sickness allowance and medical treatment. He treated respondent’s cardiovascular disease as accidental because not all fitters develop such conditions, and he concluded that respondent was entitled to the maximum amount under the CBA. He also found the company-designated physician’s findings ambiguous for failing to give a definite assessment of fitness and for leaving the medical conditions unresolved. The Labor Arbiter accordingly deemed respondent totally and permanently disabled and awarded total and permanent disability benefits and attorney’s fees, with petitioners held jointly and severally liable.

NLRC Ruling

Petitioners appealed. The NLRC Fifth Division, in its decision dated September 28, 2016, reversed the Labor Arbiter. It found no substantial evidence establishing the causal connection between respondent’s work as a fitter and his heart disease. Relying on medical references, the NLRC stated that aortic valve stenosis could be caused by genetics, aging, and childhood rheumatic disease, and that lifestyle choices may aggravate it. Since these causes were natural, it held the illness could not be accidental. It also discounted Dr. Vicaldo’s findings because no diagnostic tests were performed by him; his recommendation was merely based on examinations already conducted by the company-designated physician.

The NLRC further reasoned that, under the POEA-SEC and the CBA, respondent failed to prove his illness was work-related and therefore was not compensable. Accordingly, it dismissed the complaint for lack of merit.

Court of Appeals Proceedings

Respondent then sought relief in the Court of Appeals via a Rule 65 petition. In its February 15, 2018 decision and May 9, 2018 resolution, the CA reversed the NLRC and reinstated the Labor Arbiter’s decision.

The CA held that respondent’s illness was work-related. It initially noted that it found no evidence of how respondent’s work caused or contributed to the aggravation of his condition, yet it still concluded compensability based on two principal considerations. First, it observed that respondent did not exhibit signs of illness when hired: his PEME recorded blood pressure of 130/80 mmHg, and his chest x-ray and ECG were normal, leading to a declaration of fitness. It reasoned that he showed symptoms only during the performance of work on board and invoked Section 32-A of the POEA-SEC to infer a causal relationship.

Second, the CA relied on judicial notice and prior cases to conclude that seafarers are exposed to harsh sea conditions, long hours, family separation stress, and bodily wear and tear, and it described cardiovascular diseases as generally compensable. It also faulted petitioners for allegedly failing to present coronary angiography results and criticized the company-designated physician’s progress report for what it described as a misleading statement about an “avanabus oitpin” anomaly. The CA treated petitioners’ failure to present the angiography results as giving rise to a presumption that the evidence would be prejudicial. It further interpreted the supposed anomaly as potentially indicating a condition that rarely happens, and it noted an absence of proof whether respondent was treated and whether he could work again without putting his life at risk. The CA therefore found that the NLRC committed grave abuse of discretion in deleting the Labor Arbiter’s award.

Issues Presented

The core issue before the Supreme Court was whether respondent was entitled to disability compensation under the POEA-SEC and/or the CBA. Petitioners challenged the CA’s conclusion of work-relatedness and maintained that respondent failed to establish the required causal connection between his job duties and his heart disease. They also attacked the evidentiary basis of Dr. Vicaldo’s medical certificate and the CA’s reliance on presumptions and generalized judicial notice.

Contentions of the Parties

Petitioners argued that passing the PEME did not prove that respondent contracted the disease because the tests required to diagnose the condition were not conducted during PEME. They stressed that the company-designated physician stated that the disease etiologies were hereditary/genetic or childhood rheumatic infection and that ECG findings are not definitive for diagnosing aortic stenosis, while the proper tests were stress test and 2D echocardiography. They also argued that the CA improperly relied on presumptions rather than the substantial evidence required in labor compensation proceedings. Further, they contended that Dr. Vicaldo’s impediment grade was unsubstantiated, as the doctor did not perform confirmatory tests.

Respondent, for his part, defended the CA’s reinstatement of the Labor Arbiter’s award. He argued that he was declared fit during PEME but developed the illness while working onboard, and that the company-designated physician did not categorically state fitness or definitive total and permanent disability. He asserted that Dr. Vicaldo’s assessment should prevail, and he invoked the effects of non-referral to a third doctor under the Third-Physician Rule, as well as the doctrine that injuries or conditions with disability grading from two to fourteen and incapacity for more than the statutory period can be deemed total and permanent, citing decisions including Eyana v. Philippine Transmarine Carriers, Inc.

Supreme Court’s Ruling on Review

The Supreme Court granted the petition. It framed the matter as hinging on whether the CA and NLRC findings were conflicting, which justified review of factual matters as an exception to the general rule that factual findings are not reviewable under Rule 45. The Court explained that overseas seafarer disability claims require both medical and legal determinations. It anchored the legal framework on Articles 191 to 193 of the Labor Code, Rule X of the Rules and Regulations Implementing Book IV, and the 2010 POEA-SEC governing compensation for injuries or illness suffered during the term of employment.

The Court emphasized that under Sec

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