Case Summary (G.R. No. 210660)
Facts of the Case
Eduardo was employed for a period of ten months, commencing on June 8, 2008, with a monthly salary of $500. Prior to his embarkation, he underwent a pre-employment medical examination and was declared fit to work. On September 5, 2008, while onboard the vessel aMV Naftocement 1a, he began suffering severe pain and weakness, which led to his diagnosis of hypertension while receiving medical attention in Barbados. He was repatriated on September 7, 2008, and continued to seek medical assistance upon returning home, which proved limited until he was diagnosed with diabetes mellitus by a company-designated physician in November 2008. Unfortunately, Eduardo passed away from cardiopulmonary arrest on June 11, 2009.
Procedural History
Following Eduardo's death, his wife, Flor, sought death benefits but was met with resistance. The Labor Arbiter initially ruled in her favor, awarding benefits including $50,000 for death benefits and $1,000 for burial expenses. Status Maritime Corporation contested this decision, leading to an appeal to the National Labor Relations Commission (NLRC), which reversed the Arbiter's ruling, asserting the absence of merit in Flor's claims. The NLRC's resolution was subsequently upheld by the Court of Appeals, which ruled that benefits could not be granted since Eduardo died after the contract's expiration and that diabetes mellitus was not recognized as an occupational disease under POEA legislation.
Legal Framework
The Court of Appeals primarily referenced Section 32-A of the 2000 POEA Amended Standard Terms and Conditions, which explicitly delineates occupational diseases. Eduardo's condition of diabetes mellitus, identified as pre-existing and non-work-related, was not included in this list. There was also a focus on the applicable provisions regarding the compensability of work-related deaths and the burden of proof resting with Flor to establish a causal link between her husband's work and the conditions leading to his death.
Findings of Fact
The Court underscored that substantial evidence to establish a connection between Eduardo’s work and the illnesses leading to his death was lacking. Evidence presented indicated that he was diagnosed with diabetes and hypertension long before his employment aboard the vessel. The examination outcomes indicated no work-induced aggravation, effectively denying the claims for work-related illness and subsequent death benefits.
Conclusion of Appeals
Flor's subsequent appeals, asserting grave abuse of discretion by the NLRC and disputing the lack of causation between her husband's employm
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Case Background
- The case involves a Petition for Review on Certiorari filed by Flor G. Dayo, challenging the Decision of the Court of Appeals in CA-G.R. SP No. 118406.
- The Court of Appeals affirmed the ruling of the National Labor Relations Commission (NLRC), which had reversed the Labor Arbiter’s decision in favor of Flor.
- The primary issue revolves around the claim for death benefits following the death of Eduardo P. Dayo, who was employed as a bosun by Status Maritime Corporation for Nafto Trade Shipping Commercial S.A.
Employment Details
- Eduardo was hired for a ten-month period with a monthly salary of $500.00, and he underwent a pre-employment medical examination, which declared him fit to work.
- He boarded the vessel aMV Naftocement 1a on June 8, 2008, but experienced severe health issues, including hypertension, leading to his repatriation on September 7, 2008.
Medical History and Timeline of Events
- After returning, Eduardo sought medical assistance at the Status Maritime Corporation office but was informed that assistance was pending notification from Nafto Trade Shipping.
- He visited the Lucena United Doctors Hospital on September 9, 2008, where initial tests were normal.
- Elevated medical issues were diagnosed later, including diabetes mellitus, but medical assistance from Status Maritime ceased in February 2009.
- Eduardo died on June 11, 2009, due to cardiopulmonary arrest.
Legal Proceedings and Findings
- Flor Dayo sought death benefits, which w