Case Summary (G.R. No. 247221)
Medical Condition and Repatriation
By February 2015, Salas began experiencing significant health issues, including weakness, fatigue, loss of appetite, and sleeping difficulties. After medical examinations in Brazil, he was diagnosed with diabetes mellitus and gouty arthritis and was repatriated to the Philippines on March 21, 2015, for further treatment.
Medical Evaluation
Upon arrival, Salas was assessed by a company-designated physician who concluded that his medical conditions were non-work-related. Salas subsequently consulted an independent physician, Dr. Victor Gerardo E. Pundavela, who concluded that his conditions were related to his work as they had worsened due to repeated stress on his knees.
Legal Proceedings
Salas filed a complaint for disability benefits, moral damages, and attorney fees against his employer. The respondents contended that Salas’s conditions were pre-existing and not work-related, thus denying the claim for benefits.
Labor Arbiter's Decision
On June 28, 2016, the Labor Arbiter ruled in favor of Salas, granting him $60,000 in disability benefits, citing a sufficient causal connection between his illnesses and his employment duties. The Arbiter found that there was insufficient evidence contradicting Salas's claim regarding the aggravation of his gouty arthritis.
NLRC Reversal
The NLRC reversed the Labor Arbiter's decision on November 29, 2016, finding insufficient proof that Salas’s illnesses were work-related. The NLRC emphasized the need for substantial evidence connecting the work environment to his medical conditions, thus dismissing Salas’ case.
Court of Appeals' Ruling
The Court of Appeals upheld the NLRC's decision, finding no grave abuse of discretion. It concurred that Salas failed to demonstrate how his job contributed to his illnesses.
Supreme Court's Ruling
In examining the appeals, the Supreme Court concluded that the lower courts had erred. It determined that the presumption of work-relatedness under the 2010 POEA-SEC was not adequately rebutted by the respondents. The Supreme Court reinstated the Labor Arbiter's decision, recognizing Salas's entitlemen
...continue readingCase Syllabus (G.R. No. 247221)
Background of the Case
- The case is a petition for review on certiorari, stemming from the Decision dated February 18, 2019, and the Resolution dated May 14, 2019, of the Court of Appeals (CA) in CA-G.R. SP No. 150519.
- The CA's ruling affirmed the Decision dated November 29, 2016, and the Resolution dated January 31, 2017, of the National Labor Relations Commission (NLRC) in NLRC LAC No. (OFW-M) 09-000644-16, which found petitioner Wilfredo Lim Salas not entitled to disability benefits.
Facts of the Case
- Salas was employed as a Second Officer by Transmed Manila Corporation (TMC) for Transmed Shipping Ltd. aboard the M/V Coalmax, starting April 4, 2014, with an initial contract of eight months.
- He was declared fit for duty after a pre-employment medical examination (PEME).
- Upon contract expiration on February 9, 2015, Salas agreed to a two-month extension under the same conditions.
- In February 2015, Salas reported health issues (weakness, fatigue, loss of appetite, and sleep difficulties) and was diagnosed with diabetes mellitus and gouty arthritis in Brazil on March 21, 2015, leading to his repatriation.
- Upon returning to Manila, evaluations by company-designated physicians deemed his conditions non-work-related, citing familial/hereditary factors for diabetes and metabolic causes for gouty arthritis.
- Despite undergoing follow-up examinations, Salas claimed he was denied further medical assistance and subsequently sought an independent medical opinion from Dr. Victor Gerardo E. Pundavela, who diagnosed him with degenerative osteoarthritis and gouty arthritis, attributing his conditio