Case Summary (G.R. No. 180147)
Factual Background
On April 29, 2009, Rolando Covita entered into an employment contract with SSM Maritime Services, Inc. for a position aboard the vessel M/T Salviceroy as a Bosun, with a basic salary of US$635. He passed a Pre-employment Medical Examination (PEME) declaring him fit for sea duty. However, shortly after boarding on May 7, 2009, he experienced severe health issues, diagnosed with end-stage renal failure following hospitalization from May 14 to 21, 2009. Though he suffered chronic renal failure, a company-designated physician determined the illness was not work-related. Rolando passed away on September 20, 2009. His widow, Alma Covita, initiated a complaint for death benefits and other allowances, asserting that her husband’s illness was work-related.
Procedural History
The Labor Arbiter initially ruled in favor of Alma Covita, awarding death benefits and allowances totaling $75,000. The decision was based on findings that while Rolando died post-employment, his health complications emerged during the contract's validity and were aggravated by work conditions. The respondents appealed, and the National Labor Relations Commission (NLRC) overturned the Labor Arbiter's decision, asserting that Rolando's illness was not work-related and did not arise from his brief employment period.
Court of Appeals Decision
The Court of Appeals upheld the NLRC's decision, concluding that there was insufficient evidence to demonstrate that Rolando's chronic renal failure was contracted during his employment. It emphasized that merely claiming illness was work-related was insufficient without substantial evidence.
Legal Principles
The Court identified that for seafarers’ beneficiaries to claim death benefits, two conditions must be met: the death must be work-related and occur during the employment contract's duration. The POEA Standard Employment Contract provides that any sickness leading to death must arise from an occupational disease listed therein to be compensable. Illnesses not specified in the contract are presumed work-related, but the burden of proof falls to the claimant to establish connection and causation.
Analysis of Burden of Proof
Despite petitioner’s claims linking stress from seafaring work to Rolando's condition, the Court found arguments general and uncorroborated by medical evidence. Petitioner failed to substantiate that Rolando suffered high blood pressure or that specific work conditions contributed to worsening his health. The Court emphasized that claiming illness's work-relatedness required more than bare allegations; it necessitated credible empirical evidence.
Impact of Pre-Existing Conditions
The Court noted Rolando had only been aboard th
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Overview of the Case
- The case revolves around a petition for review on certiorari filed by Alma Covita, the surviving spouse of Rolando Covita, seeking to annul the Decision and Resolution of the Court of Appeals (CA).
- The case was decided by the Supreme Court on December 7, 2016, under G.R. No. 206600.
Background Facts
- Rolando Covita entered into an employment contract with SSM Maritime Services, Inc. for a position aboard M/T Salviceroy as a Bosun, with an initial duration of eight months and a salary of US$635.00.
- After undergoing a Pre-employment Medical Examination (PEME), Rolando was declared fit for sea duty and reported for work on May 7, 2009.
- On May 14, 2009, he exhibited symptoms of weakness and vomiting, leading to hospitalization and a diagnosis of end-stage renal failure. He was repatriated on May 23, 2009, and subsequently diagnosed with chronic renal failure.
- Rolando passed away on September 20, 2009.
Legal Proceedings Initiated by the Petitioner
- Alma Covita filed a complaint for death benefits and other allowances with the Labor Arbiter, alleging work-relatedness of Rolando's illness.
- The Labor Arbiter ruled in favor of the petitioner, granting death benefits, child allowances, and burial expenses, asserting that Rolando's illness manifested during the term of his contract.
Appeal to the NLRC
- The respondents appealed the Labor Arbiter’s decision to the National Labor Relatio