Case Summary (G.R. No. 231096)
Applicable Law
The case arose under the 2000 Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC) regarding the entitlement of benefits for seafarers, particularly in the context of work-related illness and the requisite procedures for medical examinations.
Antecedents of the Case
Gil T. Dionio, Jr. was employed on a six-month contract and later extended his contract for additional time aboard the vessel MT Caribbean Tug. He experienced health issues during his service, specifically a urinary tract infection (UTI) and prostate enlargement, which doctors confirmed rendered him unfit for work, resulting in his repatriation. Upon returning to the Philippines, Gil was told to seek medical help on his own, as ND Shipping refused to cover his medical expenses, leading him to seek treatment independently.
Labor Arbiter’s Ruling
The Labor Arbiter ruled in favor of Lorna, awarding her death benefits and other claims, emphasizing that Gil's medical condition was work-related. It was established that his illness led to his eventual death, granting basis for the claimed benefits under the provisions of the POEA-SEC.
NLRC Ruling
Contrarily, the NLRC ruled against Lorna, reversing the Labor Arbiter’s decision. It emphasized Gil's failure to comply with a post-employment medical examination within three days following repatriation, as mandated by the POEA-SEC, citing the need for proactive collaboration in understanding the causal connection between Gil's work and his illness.
Court of Appeals Ruling
The Court of Appeals upheld the NLRC’s decision, indicating that Lorna had not successfully demonstrated that Gil's illness was work-related, and reiterated the importance of the mandatory post-employment medical examination.
Arguments from Petitioner
Lorna contended that Gil complied with the post-employment examination requirement but was neglected by the respondents who did not facilitate his examination by a company physician. Lorna argued that the symptoms observed during Gil's employment were indicative of his eventual prostate cancer diagnosis and thus were work-related.
Respondents’ Defense
Respondents countered Lorna's claims by insisting she failed to show that Gil's illness was work-related. They maintained that he did not undergo a timely post-employment examination, thereby forfeiting his entitlement to benefits as per the stipulations of the POEA-SEC.
Supreme Court’s Ruling
The Supreme Court recognized the merit in Lorna's arguments and noted that substantial evidence indicated Gil had indeed complied with the requirement to report to his employer following repatriation. The Court highlighted that the employer failed to meet its obligations by not providing a medical consultation at the company’s cost, compelling Gil to pursue independent medical attention.
On Work-Relatedness and Employer Liability
The Court reiterated that under the POEA-SEC, illnesses not explicitly listed could still be presumed work-related, placing the onus on the employer to disprove such presumption. Here, symptoms presented while working aboard the vessel, including the diagnosis of UTI and prostate enlargement, afforded a sufficient link t
...continue readingCase Syllabus (G.R. No. 231096)
Case Overview
- This case is an appeal by certiorari filed by Lorna B. Dionio (petitioner) against ND Shipping Agency and Allied Services, Inc. and Caribbean Tow and Barge (Panama) Ltd. (respondents).
- The appeal seeks to reverse the Court of Appeals' decision dated February 21, 2017, which affirmed the National Labor Relations Commission's (NLRC) decisions dismissing petitioner’s claims for death benefits and other monetary claims related to the death of her husband, Gil T. Dionio, Jr.
Antecedents
- Gil T. Dionio, Jr. was hired on May 9, 2006, as a Second Engineer on the vessel MT Caribbean Tug.
- His employment was for six months at a monthly salary of US$772.00, with a clean health bill prior to employment.
- Upon contract expiration, his contract was extended until February 13, 2007.
- Gil suffered from a urinary tract infection (UTI) and prostate enlargement while on board, leading to a medical examination by Dr. Victoria Smith, who declared him unfit for work and recommended repatriation.
- Gil was medically repatriated on February 13, 2007, and arrived in the Philippines the next day, where he was issued a referral slip for medical examination at his own expense.
Medical Examination and Treatment
- Respondents denied coverage for Gil's medical examination costs, asserting he must arrange this himself.
- Gil sought medical treatment at BiAan Doctor’s Hospital at his own expense due to worsening health.
- On June 5, 2007, he was diagnosed with "Prostatic Cancer Stage IV with widespread metastasis" and subsequently received various medical treatments.
- Gil signed a Release, Waiver, and Quitclaim in favor of respondents on April 2, 2007, for P31,200.00, at a time when h