Case Summary (G.R. No. 199568)
Antecedent Facts
Andres Gazzingan was hired on October 14, 2005, as a messman on board the vessel M/V Gloria. Prior to his employment, he underwent a pre-employment medical examination, which showed normal results except for a finding of left ventricular hypertrophy. He began his duties on November 4, 2005, but experienced severe health issues while the vessel was docked in Colombia in May 2006. After being diagnosed with Acute Type-B Dissection and subsequently medically repatriated, Gazzingan faced complications in obtaining further medical care due to the petitioners' refusal to cover his medical expenses based on the assessment of their designated physician declaring his condition as non-work-related.
Proceedings before the Labor Arbiter
On August 25, 2006, Gazzingan filed a complaint for unpaid benefits, including sickness allowance and disability claims. The Labor Arbiter ruled in favor of Gazzingan, stating that despite uncertainties regarding the illness's cause, evidence suggested it could be work-related. The Arbiter ordered petitioners to pay Gazzingan total permanent disability benefits and sickness allowance.
Proceedings before the National Labor Relations Commission
Petitioners appealed the Labor Arbiter’s decision to the National Labor Relations Commission (NLRC), which ruled against Gazzingan, favoring the opinion of the company-designated physician that his condition was not work-related. The NLRC focused on Gazzingan’s smoking history and previous health conditions as factors negating work-relatedness.
Proceedings before the Court of Appeals
Respondents, as heirs of Gazzingan, filed a petition for certiorari with the Court of Appeals, arguing the NLRC abused its discretion. The appellate court found that the evidence did not sufficiently support the claim that Gazzingan's illness was congenital. Instead, it reinstated the Labor Arbiter's findings regarding the work-related nature of Gazzingan’s illness.
Issues Raised
The core issues presented for resolution included:
- The work-relatedness of Gazzingan's illness.
- The authority of the company-designated physician in determining the work connection.
- The burden of proof with respect to demonstrating work-relatedness.
- Whether claimants could rely on disputable presumptions of work relation without additional medical evidence.
- The implications of sickness allowance payments on the petitioners' obligations.
- Entitlement to attorney's fees in the absence of bad faith.
Ruling and Findings
The Supreme Court ruled against the petitioners, affirming the CA decision. It found that Gazzingan's condition of aortic dissection was work-related based on the strenuous physical nature of his job, which likely exacerbated his health condition. The Court underscored that mere genetic predisposition or smoking did not negate the significant connection between Gazzingan's work and his illness.
Basis for Compensability
Citing the POEA-SEC, the Court emphasized that for an illness to be compensable, it must be shown that it is work-related and occurred during the term of employment. The case established that illnesses not specifically listed as occupati
...continue readingCase Syllabus (G.R. No. 199568)
Overview
- This case involves a petition for review on certiorari by Dohle-Philman Manning Agency, Inc., Dohle (IOM) Limited, and Captain Manolo T. Gacutan against the heirs of Andres G. Gazzingan concerning the legal recognition of Gazzingan's illness as work-related under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).
- The Court of Appeals ruled in favor of Gazzingan's heirs, reversing the National Labor Relations Commission's (NLRC) decision which had found that Gazzingan's condition was not work-related.
Background
- Gazzingan was employed as a messman on the vessel M/V Gloria for nine months, earning a basic salary of US$325.00.
- Prior to his employment, Gazzingan underwent a pre-employment medical examination (PEME) which indicated normal results except for left ventricular hypertrophy.
- While working in May 2006, he experienced severe chest pains, leading to a diagnosis of Acute Type-B Dissection after hospitalization in Colombia.
Medical Assessment and Disputes
- Upon repatriation to Manila, he was diagnosed with a dissecting aneurysm.
- The company-designated physician, Dr. Raymond C. Banaga, declared Gazzingan's condition as non-work-related, asserting it was congenital and not compensated under the POEA-SEC.
- Gazzingan contested this opinion, arguing that his work conditions contributed to his medical condition.
Labor Arbiter's Decision
- Gazzingan filed a complaint for non-payment of benefits, leading to a Labor Arbiter's ruling which found that his illness was work-related and ordered compensation of US$50,000 in permanent dis