Case Summary (G.R. No. 234914)
Facts of the Case
Jorge P. Rosales was employed by Singa Ship Management Phils., Inc. and Singa Ship Management Pte. Ltd. under a POEA-SEC which outlined specifics of his employment such as duration, position, salary, working hours, and benefits. Rosales was declared "FIT" for duty after his pre-employment medical examination. He was deployed on November 26, 2012, aboard the ship Queen Mary 2, where he was responsible for cleaning, waste management, and maintaining sanitary conditions.
Starting June 25, 2013, Rosales experienced abdominal pain and joint issues, leading to his medical repatriation on July 20, 2013. He consulted the company-designated physician upon his return; he was treated for gastritis and later diagnosed with chronic Hepatitis C, which was exacerbated by his medical history.
Ruling of the Labor Arbiter
The Labor Arbiter dismissed Rosales's complaint for permanent total disability benefits, agreeing with the respondents that his illnesses were not work-related. However, the Labor Arbiter ordered the respondents to pay Rosales for sickness allowance and financial assistance, highlighting that he fell ill while aboard and was repatriated before the contract's expiration.
Ruling of the National Labor Relations Commission
On appeal, the National Labor Relations Commission (NLRC) found Rosales's Hepatitis infection to be an occupational disease linked to his employment, thus declaring it work-related. The NLRC modified the Labor Arbiter's ruling by awarding Rosales permanent total disability compensation and attorney's fees, while dismissing the financial assistance award previously granted.
Ruling of the Court of Appeals
The Court of Appeals (CA) annulled the NLRC's decision, ruling that Rosales failed to present sufficient evidence to prove his Hepatitis C and fatty liver conditions were work-related. The CA ordered the respondents to pay Rosales financial assistance of $5,000 as a humanitarian measure.
Issues
The critical issues addressed in the petition included whether Rosales's chronic Hepatitis C and fatty liver conditions were work-related and compensable, and whether he was entitled to full disability benefits.
Ruling of the Court
The Supreme Court concluded that Rosales's chronic Hepatitis C and fatty liver were work-related, establishing that Chronic Hepatitis C is a bloodborne virus often contracted in occupational settings, particularly in healthcare or sanitary roles, such as Rosales’s. The ruling emphasized that while not explicitly listed as an occupational disease in the POEA-SEC, the disease should be considered disputably presumed work-related, underscoring a reasonable connection between Rosales's employment duties and the contraction of the virus.
Entitlement to Benefits
The Court also ruled that Rosales is entitled to permanent total disability benefits, given that he had not received a definitive assessment from the company-designated physician within the required timeframe, further enforcing the presumption of total and permanent disability entitlement. His entitlement included sickness allowanc
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Case Background
- This case involves a Petition for Review on Certiorari filed under Rule 45 of the 1997 Rules of Civil Procedure by Jorge P. Rosales against Singa Ship Management Phils., Inc., Singa Ship Mgt. Pte. Ltd., and Ms. Norma L. David.
- The petition challenges the Decision dated April 24, 2017, of the Court of Appeals (CA) in CA-G.R. SP No. 139921, which annulled and set aside prior rulings from the National Labor Relations Commission (NLRC) regarding Rosales’ claims for disability benefits.
Facts of the Case
- Jorge P. Rosales was employed as a steward under a Philippine Overseas Employment Agency-Standard Employment Contract (POEA-SEC) for a duration of eight months with a monthly salary of USD 327.00.
- He underwent a pre-employment medical examination and was deemed "FIT" for duty.
- Rosales began his employment aboard the vessel Queen Mary 2 on November 26, 2012, with specific duties related to maintaining cleanliness and sanitation on board.
- On June 25, 2013, he reported abdominal muscle and joint pains, which persisted despite medical consultations.
- He was repatriated on July 20, 2013, and diagnosed with various conditions, including Chronic Hepatitis C after a series of evaluations.
Ruling of the Labor Arbiter
- The Labor Arbiter dismissed Rosales’ complaint for permanent total disability benefits, concluding that his illness was not work-related.
- However, the Labor Arbiter ordered respondents to pay Rosales a total of USD 2,352 for sickness allowance, USD 5,000 for financial assistance,