Case Summary (G.R. No. 154684)
Background and Employment Details
Mario H. Ong was first employed by BW Shipping Philippines, Inc. in January 1999 and was subsequently promoted on multiple occasions. He was last hired on March 19, 2008, as the Chief Steward and Chief Cook for a duration of nine months on the vessel BW Hemina, earning a monthly salary of USD 1,127. Prior to his embarkation on March 29, 2008, Ong underwent a medical evaluation by company-designated physicians and was declared fit for sea duty.
Illness and Medical Condition
On June 8, 2008, Ong began experiencing various health issues, including dizziness and shortness of breath. Following a consultation on June 17, he was diagnosed with uncontrolled diabetes and hypertension, leading to his repatriation on June 20, 2008, for further evaluation and treatment by company-designated physicians. Despite being certified fit to work on October 2, 2008, Ong reported that his health condition did not improve, prompting him to seek an independent medical opinion.
Legal Proceedings Initiated by the Respondent
Seeking financial support for his medical expenses, Ong filed a complaint against the petitioners, requesting permanent disability benefits, medical reimbursements, damages, and attorney’s fees. The Labor Arbiter, Enrique L. Flores, ruled in Ong's favor on June 19, 2009, granting him USD 90,000 in disability benefits based on the premise that his illness arose during his employment.
Appeals and Decisions by Labor Organizations
The petitioners appealed the Labor Arbiter's decision to the National Labor Relations Commission (NLRC), which upheld the ruling on October 27, 2009, while emphasizing that it was vital for the illness to be work-related for compensability. A subsequent motion for reconsideration was denied on December 22, 2009.
Court of Appeals Ruling
In 2012, following a petition for certiorari filed by the petitioners, the Court of Appeals affirmed the NLRC's decision, noting that although Ong was declared fit to resume duties, he remained unable to work due to his ongoing health issues. The appellate court found that Ong had sufficiently demonstrated the work-related nature of his illnesses.
Supreme Court's Review Standard
The Supreme Court reviewed the case under the jurisdiction established for labor cases, focusing on whether the Court of Appeals correctly identified any grave abuse of discretion perpetrated by the NLRC. It reiterated that such determination is rooted in whether the decisions of lower tribunals are supported by substantial evidence.
Findings on Disability Benefits Denied
The Supreme Court concluded that Ong was not entitled to permanent total disability benefits. The requisite burden of proof under Section 20(B) of the 2000 POEA-SEC was not met, specifically regarding the employee's obligation to show that his conditions were work-related and existed during the term of his employment contract.
Nature of Diabetes and Hypertension
The Supreme Court classified diabetes mellitus as a non-occupational disease since it stemmed from hereditary factors and lifestyle choices. It highlighted that essential hypertension could qualify as an occupational disease under specific conditions, which Ong failed to substantiate. Consequently, the Court deemed that Ong's inability to demonstrate how his work duties contributed to his diabetes and hypertension negated his claims for compensation.
Evaluation of Medical Evidence
The judgment emphasized the precedence of evaluations made by company-designated physicians, no
...continue readingCase Syllabus (G.R. No. 154684)
Case Overview
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court.
- Petitioners are BW Shipping Philippines, Inc., BW Gas ASA/Norway, and Rolando C. Adorable, while the respondent is Mario H. Ong.
- The petition seeks to annul and set aside the Decision of the Court of Appeals (CA) in CA-G.R. SP No. 112793 dated March 9, 2012, and its Resolution dated June 4, 2012.
- The CA's Decision affirmed the Resolutions of the National Labor Relations Commission (NLRC) dated October 27, 2009, and December 22, 2009.
Antecedent Facts
- Respondent Mario H. Ong was first hired by the petitioner in January 1999 and was promoted multiple times over nine years.
- On March 19, 2008, Ong began his employment as Chief Steward and Chief Cook on the BW Hemina, with a nine-month contract and a monthly salary of USD 1,127.00.
- Ong was declared "fit for sea duty" by company-designated physicians prior to his embarkation on March 29, 2008.
- Ong's responsibilities included managing food supplies, supervising crew meals, and preparing reports for port authorities.
Medical Issues and Repatriation
- Ong experienced various health issues, including dizziness and shortness of breath, and was diagnosed with "uncontrolled diabetes and uncontrolled hypertension" on June 17, 2008.
- He was repatriated on June 20, 2008, and underwent further medical evaluations, which included medication recommendations.
- On October 2, 2008, the company-designated physicians declared Ong "fit to resume sea duties."
Subsequent Medical Opinions
- Despite the company’s findings, Ong consulted Dr. Antonio C. Pascual, who diagnosed him with "Essential Hypertension, Stage 2 and Diabetes Mellitus, Type 2," with no prior history of such conditions.
- Ong sought financial assistance from the petitioner for medical expenses, which was refused, leading to his filin