Case Summary (G.R. No. 253756)
Employment and Medical Background
Petitioner was hired on March 29, 2016, with a contract for ten months. Prior to deployment, he underwent a Pre-Employment Medical Examination (PEME), passing as fit for sea duties except for prescribed medication for hypertension. Petitioner performed various strenuous physical duties that required prolonged standing and heavy lifting. Two months into his tenure, petitioner experienced back pain after a forceful movement to pull a generator piston lining, leading to gradual worsening of his condition.
Medical Diagnosis and Repatriation
Petitioner was medically repatriated on June 6, 2016, after being diagnosed with lower back muscle spasm and thoracolumbar spondylodiscitis complicated by spinal tuberculosis (granulomatous inflammation with necrosis). The company-designated physician, Dr. Natalio Alegre, concluded that spinal tuberculosis was a non-work-related illness originating from a latent childhood infection. Respondents stopped medical assistance based on this finding.
Petitioner’s Continued Medical Treatment and Complaint
Disputing respondents’ non-compensability, petitioner contended that other spinal pathologies such as degenerative disc disease and spondylolisthesis were inadequately addressed. He sought treatment independently at Philippine General Hospital. An orthopedic specialist, Dr. Renato A. Runas, assessed him in January 2017 and declared him unfit for sea duties, attributing pain to vertebral displacement and aggravated conditions due to lifting and prolonged standing.
Labor Arbiter’s Ruling
Labor Arbiter Thomas T. Que, Jr. ruled in favor of the petitioner, awarding total and permanent disability benefits of USD60,000, sickness allowance of USD3,000, moral and exemplary damages of PHP250,000 each, and attorney’s fees of 10%. The Labor Arbiter emphasized the onset of symptoms only after deployment, the failure of respondents to assess all injuries (including spondylolisthesis), and the legal standard of establishing mere possibility—rather than certainty—of work-connection.
NLRC’s Reversal
Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s decision, dismissing the claim for disability benefits due to failure to prove causation between work and spinal injuries. It held that petitioner’s back pain predated deployment and that concealment of this constituted disqualification under the POEA-SEC. However, the NLRC granted sickness wages for the period between repatriation and the declaration of non-work-related status. The motion for reconsideration was denied by the NLRC.
Court of Appeals’ Affirmance
The Court of Appeals (CA) affirmed the NLRC. It found that medical evidence did not sufficiently connect petitioner’s spinal tuberculosis to his work and favored the company-designated physician’s findings over the later orthopedic opinion, especially as petitioner’s symptoms allegedly predated deployment. The CA also emphasized the lack of competent corroboration aside from petitioner’s narrative.
Petitioner’s Grounds for the Present Petition
Petitioner argued: (1) no final and definitive medical assessment was issued except the report finding spinal tuberculosis non-work-related; (2) he had no pre-existing spinal condition prior to boarding, as confirmed by the PEME; (3) probability, not absolute certainty, is the standard for compensability; and (4) the absence of a ship log report or accident documentation is not fatal to his claim, consistent with Philippine jurisprudence.
Respondents’ Position
Respondents maintained that petitioner’s spinal tuberculosis was a latent childhood infection not aggravated or caused by work, hence not compensable. They also underscored petitioner’s failure to provide accident documentation or substantiated evidence linking his alleged injuries to work aboard the vessel. They argued that sickness allowances paid during treatment sufficed and no additional compensation was warranted.
Legal Issues
- Whether petitioner committed material concealment of a pre-existing medical condition.
- Whether petitioner is entitled to total and permanent disability benefits.
Material Concealment: Court’s Findings
The Court clarified that an illness is considered pre-existing under the 2010 POEA-SEC if a seafarer was advised of continuing treatment by a doctor or knowingly concealed a diagnosed condition that cannot be detected in a PEME. The Court rejected the NLRC and CA’s conclusions of concealment, emphasizing the absence of evidence establishing that petitioner deliberately concealed any back condition with the intent to deceive or gain compensation—including no indication that petitioner admitted to a history of back pain during PEME or prior medical consultations. Petitioner passed PEME and was declared fit, showing no work limitations before deployment. Therefore, there was no material concealment disqualifying him from benefit claims.
Entitlement to Disability Benefits: Applicable Law
The employment relationship is governed by the POEA-SEC as integrated into the employment contract. Under the 2010 POEA-SEC, employers are liable to pay compensation and provide medical treatment for work-related injuries or illnesses, continuing through the seafarer’s repatriation and until declared fit or disability grading is established by the company-designated physician. Disability ratings must be assessed and communicated within 120 days, extendable up to 240 days with justification; failure to provide final assessment renders the disability permanent and total by operation of law. Occupational diseases must satisfy four conditions: (a) involving inherent risk of the work; (b) contracted from exposure to said risk; (c) contracted during exposure period; and (d) absent wilful negligence by the seafarer.
Causal Relationship and Medical Conditions
Despite the spinal tuberculosis diagnosis, petitioner exhibited degenerative disc disease and spondylolisthesis, demonstrated by x-ray and MRI findings, all conducive to severe pain and limited mobility. The Court noted that these conditions were consistent with occupational diseases under the POEA-SEC, particularly given petitioner’s strenuous duties involving heavy lifting and prolonged physical exertion. His symptoms surfaced after a noted incident on board, bolstering the reasonable probability of work-related causation. The Court cited precedent affirming that reasonable probability—not absolute certainty—is the evidentiary standard in seafarer compensation claims.
Failure to Assess and Communicate Disability Rating
Respondents stopped medical assistance after declaring spinal tuberculosis not work-related and failed to provide any definitive medical assessment regarding petitioner’s degenerative disc disease and spondylolisthesis, despite repeated requests. Consistent with jurisprudence, the absence of a final medical assessment within the statutory timeframes causes the seafarer’s disability to be deemed perm
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Case Syllabus (G.R. No. 253756)
Background and Procedural History
- The petitioner, Resty S. Caampued, was hired as an Engine Fitter by Next Wave Maritime Management, Inc., on behalf of MTM Ship Management Pte. Ltd., for a ten-month contract starting March 29, 2016, with a monthly salary of USD649.00.
- Prior to deployment, petitioner underwent a Pre-Employment Medical Examination (PEME) wherein he was declared fit for sea duties despite being prescribed medication for hypertension.
- Within two months of deployment aboard the vessel "MV Red Cedar," petitioner sustained back injury during work, resulting in persistent low back pain.
- Medical examinations revealed multiple spinal conditions including degenerative disc, spondylolisthesis, and spinal tuberculosis.
- Petitioner was medically repatriated to the Philippines on June 6, 2016.
- Petitioner filed a claim for total and permanent disability benefits which was initially granted by the Labor Arbiter, but later reversed by the NLRC and the Court of Appeals.
- The petitioner elevated the case to the Supreme Court via a petition for review on certiorari seeking reversal of the Court of Appeals’ decisions.
Facts Concerning Petitioner’s Employment and Injury
- Petitioner’s job involved physically strenuous tasks such as fabrication of metals, lifting heavy items, repairing machinery, and continuous standing and movement.
- Incident occurred in May 2016 where petitioner, while squatting, forcefully pulled a piston lining inside the ship’s generator resulting in an audible snap and subsequent back pain.
- Initial medical treatment onboard involved pain relievers, but pain persisted severely leading to consultation in Africa where he was diagnosed with several spinal disorders including thoracolumbar spondylodiscitis and grade 2 L5-S1 spondylolisthesis.
- Further diagnostics, including X-rays and MRI, revealed degenerative disk disease, compression deformities, and a paravertebral soft tissue mass suggestive of infectious or malignant processes.
- Biopsy confirmed spinal tuberculosis, which respondents argued was a pre-existing, childhood latent disease not work-related.
- Despite petitioner’s requests, respondents allegedly did not treat or assess all his spinal injuries, notably ignoring the degenerative disc disease and spondylolisthesis.
Medical Findings and Assessment
- Company-designated physician, Dr. Natalio Alegre, concluded spinal tuberculosis was pre-existing and non-work-related.
- Petitioner’s MRI and x-ray reports showed degenerative disc disease and spondylolisthesis, which remained untreated and unassessed by company physicians.
- Another orthopedic specialist, Dr. Renato A. Runas, concluded petitioner was unfit for sea duty citing persistent pain and limited movement due to displacement of vertebrae.
- Petitioner continued medical treatment in the Philippines at his own expense but stopped due to financial constraints.
- No final, definite medical assessment or disability grading for degenerative disc disease and spondylolisthesis was issued by company doctors.
Labor Arbiter’s Decision
- Labor Arbiter Thomas T. Que, Jr. granted petitioner’s claim for total and permanent disability benefits amounting to US$60,000, sickness allowance, moral and exemplary damages, and attorney’s fees.
- His conclusions were based on the fact that petitioner was fit at the time of PEME, showed symptoms only after the piston lining incident, and respondents failed to address all causes of injury.
- Held that mere possibility or probability of work-relatedness suffices in claims for compensation.
- Unaddressed spinal conditions, specifically spondylolisthesis, were deemed to qualify for total