Title
Lacson vs. RCCL Crew Management Inc., et al.
Case
G.R. No. 270817
Decision Date
Jan 27, 2025
Lacson sought disability benefits after suffering from skin conditions due to work exposure on a vessel. The court evaluated medical evidence and procedural compliance regarding assessments of his condition and entitlements.
permanent disability
total disability
employers liability

Case Summary (G.R. No. 270817)

Factual Background

Petitioner signed his employment contract with RCCL on January 30, 2018 for placement with Royal Caribbean Cruises Ltd. He boarded the vessel Azamara Quest and started work as AZ Commis 2. His onboard duties included food preparation and kitchen sanitation. In performing these functions, he was exposed to cleaning materials and chemical agents, including sanitizers, bleaches, acids, degreasers, and detergents.

After a few months, petitioner developed skin itching. He was given a steroidal cream by the ship doctor, but his condition persisted and worsened into painful skin rashes and blisters on his hands and other parts of his body. He was then referred to a shore physician/dermatologist in Italy, where he was diagnosed with allergic dermatitis. On August 20, 2018, he was medically repatriated to the Philippines for further treatment.

On August 24, 2018, the company-designated physician Shiphealth, Inc. (Shiphealth) diagnosed him with contact dermatitis with secondary bacterial infection. Petitioner underwent post-employment medical evaluations and treatments until January 17, 2019. Despite the visible rashes, RCCL asked him to report for redeployment and instructed him to continue with his medications.

Because his rashes persisted, petitioner sought further medical consultation at Seamen’s Hospital, and in a medical certificate dated February 6, 2019, he was diagnosed with hand dermatitis (noted as RIO allergic contact dermatitis) and declared “UNFIT for duty at the time of the examination.” On February 20, 2019, he consulted Casa Medica Inc., where Dr. Miguel Maralit diagnosed him with dyshidrotic eczema and nummular eczema. Dr. Maralit declared petitioner unfit to work in the kitchen and advised transfer to another department.

Petitioner filed a complaint for permanent and total disability benefits on March 18, 2019.

Respondents’ Account and Medical Records

Respondents contested the claim. They pointed to petitioner’s Medical Certificate For Service at Sea where petitioner admitted having allergies/anaphylaxis attributed to environmental factors, chemicals, foods, or medications. They also claimed that petitioner complained of pruritic lesions soon after boarding in April 2018.

Respondents relied heavily on Shiphealth’s medical history and assessments. On August 24, 2018, petitioner allegedly reported persistent pruritic lesions on multiple body areas, and Shiphealth diagnosed contact dermatitis with secondary bacterial infection and prescribed medication. Shiphealth records showed ongoing weekly consultations. During an October 17, 2018 re-evaluation, petitioner reported reduction of pruritic lesions. By December 10, 2018, his condition had significantly improved, with only minimal lesions remaining. Intralesional steroid injections were administered on December 13, 2018, January 3, 2019, and January 10, 2019.

On January 17, 2019—151 days from repatriation—Shiphealth issued a Final Report stating that pruritic lesions had resolved and that petitioner had no other subjective complaints. The final diagnosis was “Nummular Eczema, resolved.” On January 24, 2019, petitioner was declared fit for duty, as no further medical intervention was deemed necessary.

Proceedings Before the Labor Arbiter

In a Decision dated October 17, 2019, the Labor Arbiter dismissed the complaint. The Labor Arbiter reasoned that petitioner failed to comply with the third-doctor rule, and it held there was no merit to petitioner’s argument that there was no final and definite assessment. The Labor Arbiter concluded that, absent a third doctor opinion, the findings of Shiphealth were final and binding.

Review by the NLRC

Petitioner appealed to the NLRC. In a Decision dated February 26, 2021, the NLRC affirmed the Labor Arbiter’s dismissal and sustained the ruling that Shiphealth’s assessment controlled the resolution of the disability claim.

The Court of Appeals Ruling

Petitioner then filed a certiorari petition with the Court of Appeals in CA-G.R. SP No. 171761. The CA dismissed the petition. It found that petitioner’s claim for permanent and total disability had no factual or legal basis. The CA reasoned that Shiphealth’s medical records justified extending petitioner’s initial 120-day treatment period, and it treated Shiphealth’s assessment dated January 17, 2019 as valid, final, and definite. It also held that Shiphealth was more qualified than petitioner’s doctors because the latter’s assessments were based on single examinations and existing records.

The CA rejected petitioner’s argument that his disability became permanent and total solely because he remained disabled for more than 240 days from repatriation. It stated that the record lacked facts on the time period when petitioner was declared fit for duty and the period when he claimed permanent disability benefits. The CA also found no evidence that petitioner re-applied for work and was declared unfit due to his illness. It ultimately held there was no proof that petitioner was still suffering from the skin disease during the claim period.

The CA denied petitioner’s motion for reconsideration on October 10, 2023, prompting the present petition.

Petitioner’s Arguments in the Supreme Court

Petitioner argued that courts are not automatically bound by company-designated physician findings and that such findings may be disregarded if unsupported by medical records. He assailed the Final Report dated January 17, 2019 as defective because the report did not disclose the signatory doctor’s name, specialty, or expertise. He claimed that the report referred to “Dermatology service” for clearance, which he argued did not necessarily refer to the signatory physician. He further maintained that it was unclear whether the signatory was even a medical doctor or a dermatologist.

Petitioner also contended that the Final Report’s statement that he was “cleared” was indefinite and not equivalent to the legal requirement of a final fitness-to-work declaration. He further maintained that he first saw the Final Report only when respondents submitted their position paper, which petitioner argued was beyond the relevant statutory periods. Thus, petitioner asserted that his disability became permanent and total by operation of law due to respondents’ failure to issue a proper final assessment within the required timeframe.

Respondents’ Defenses

Respondents argued that the petition raised factual questions beyond the Supreme Court’s jurisdiction under Rule 45 review. They urged that petitioner’s allegations required a re-evaluation of facts because they believed the accurate factual background was not fully presented.

They also maintained that petitioner had a pre-existing condition or at least a history of allergy, pointing to the Medical Certificate for Sea Service. They emphasized that petitioner allegedly reported skin lesions soon after boarding, and they argued that petitioner falsely claimed he had been well for months before the onset. Respondents further argued that petitioner’s condition was not work-related, that it was not a listed occupational disease under Section 32(A) of the POEA-SEC, and that even if it were presumed work-related, petitioner failed to show a causal connection between his illness and his contracted work.

They also argued that assuming the illness was work-related, petitioner was eventually declared fit for work, with the ailment resolved as shown in Shiphealth’s Final Report. They contended that the company-designated physician’s assessment was final, definite, and conclusive, and that petitioner had failed to refer alleged conflicts to a third doctor. Respondents also asserted that loss of earning capacity alone did not entitle petitioner to maximum disability benefits and that petitioner failed to prove Grade 1 disability to qualify for full benefits.

Core Issues

The principal issue before the Court was whether petitioner was entitled to permanent and total disability benefits.

The Supreme Court’s Approach to Review

The Supreme Court recognized that the issue of entitlement to disability benefits is factual in nature. Generally, in a petition for review under Rule 45, only questions of law are allowed. Factual findings of lower courts are ordinarily final. The Court nonetheless held that an exception applied because the CA manifestly overlooked undisputed facts that would have justified a different conclusion. Accordingly, the Court re-evaluated the factual record.

Governing Law on Compensability Under the POEA-SEC

The Court held that entitlement to disability benefits is governed by law, by the employment contract, and by the medical findings. Under Section 20(A) of the 2010 POEA-SEC, the employer is liable when (1) the seafarer suffers a work-related injury or illness, and (2) the illness or injury existed during the term of the contract.

The Court reiterated that illnesses not listed under Section 32 are disputably presumed work-related. It cited Reyes v. Jebsens Maritime, Inc. for the proposition that the presumption is legal and favorable to seafarers, but does not automatically grant benefits. The seafarer still must provide substantial evidence of a reasonable causal connection, while the employer bears the burden to disprove work-relatedness.

Work-Relatedness of Petitioner’s Nummular Eczema

The Court examined respondents’ reliance on petitioner’s Medical Certificate for Sea Service regarding allergies/anaphylaxis to environmental factors, chemicals, foods, or drugs. The Court found that petitioner’s “Yes” answer concerned specific allergens—latex and nickel—as reflected in the record. It held that this did not support a claim that petitioner had a generalized pre-existing allergy to the environment or chemicals generally. The Court also noted that the record did not show petitioner was exposed to latex or nickel during his work as AZ Commis 2.

The Court further held that compensability does not depend on whether the illness was pre-existing

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