The Supreme Court held that a seafarer’s illness, even if not directly listed as an occupational disease, can be compensable if the working conditions contributed to its development or aggravation. This ruling emphasizes the importance of a liberal interpretation of the POEA-SEC in favor of seafarers, especially when their work environment and dietary provisions at sea contribute to the onset or worsening of a disease. The court prioritized the seafarer’s welfare, reinforcing the principle that the POEA-SEC should be applied fairly and reasonably to protect Filipino seafarers working on ocean-going vessels.

From Oiler to Patient: Can a Seafarer’s Diet and Labor Lead to Disability Compensation?

This case, Skippers United Pacific, Inc. v. Lagne, revolves around Estelito Lagne, an oiler who developed rectosigmoid adenocarcinoma during his employment. Lagne sought disability benefits, arguing his condition was work-related due to the food provisions on the ship and the strenuous nature of his job. The petitioners, Skippers United Pacific, Inc., contested this, arguing that Lagne’s illness was not listed as an occupational disease under the POEA-SEC. The central legal question is whether Lagne’s illness is compensable under the POEA-SEC, considering it is not explicitly listed as an occupational disease, and whether there is sufficient evidence to link his working conditions to the development or aggravation of his condition.

The Supreme Court addressed the compensability of Lagne’s illness by examining the requirements under Section 20(B)(4) of the POEA-SEC, which requires that the injury or illness must be work-related and must have existed during the term of the seafarer’s employment contract. The Court noted that while rectosigmoid adenocarcinoma is not listed under Section 32 of the POEA-SEC, the agreement creates a disputable presumption that illnesses not listed are work-related. However, the seafarer must still present substantial evidence demonstrating that their work conditions caused or increased the risk of contracting the disease. In this case, Lagne’s duties as an oiler, which included heavy lifting and exposure to conditions that aggravated his condition, were taken into account.

Building on this principle, the Court considered the NLRC’s findings regarding the food provisions on the ship, which consisted mostly of frozen meat and canned goods, lacking fresh vegetables. This dietary condition was deemed a contributing factor to Lagne’s rectal illness. The Court cited Leonis Navigation Co., Inc., et al. v. Heirs of the late Catalino V. Villamater, et al., emphasizing that factors such as high fat intake and genetics can increase the risk of colorectal cancer. In that case, the Supreme Court had already weighed in on risk factors regarding colorectal cancer. To put it in perspective, the Supreme Court quoted the previous ruling:

Factors that increase a person’s risk of colorectal cancer include high fat intake, a family history of colorectal cancer and polyps, the presence of polyps in the large intestine, and chronic ulcerative colitis.

Diets high in fat are believed to predispose humans to colorectal cancer. In countries with high colorectal cancer rates, the fat intake by the population is much higher than in countries with low cancer rates. It is believed that the breakdown products of fat metabolism lead to the formation of cancer-causing chemicals (carcinogens). Diets high in vegetables and high-fiber foods may rid the bowel of these carcinogens and help reduce the risk of cancer.

The Court also highlighted the appellate court’s findings that the interplay of age and dietary factors contributed to Lagne’s condition, as he was 55 years old at the time of signing his employment contract, an age at which the incidence of rectosigmoid cancer is more likely. Dr. Go, the company-designated doctor, acknowledged that risk factors for rectosigmoid adenocarcinoma include age and a diet rich in saturated fat. The Court reiterated that it is sufficient if the employment contributed even in a small degree to the development of the disease, and the employer assumes the risk of liability even if the ailment was contracted prior to employment.

As to the sickness allowance, the Court affirmed its award in favor of Lagne, as there was no evidence on record that the petitioners had duly paid it. Moreover, the petitioners did not dispute that Lagne was repatriated for medical reasons. According to Section 20 (B) (3) of the POEA-SEC:

Upon sign off from the vessel for medical treatment, the seafarer is entitled to sickness allowance equivalent to his basic wage until he is declared fit to work or the degree of permanent disability has been assessed by the company-designated physician but in no case shall the period exceed one hundred twenty (120) days.

Regarding the award of attorney’s fees, the Court found it justified because Lagne was compelled to litigate due to the petitioners’ failure to satisfy his valid claim. Where an employee is forced to litigate to protect their rights, they are entitled to attorney’s fees equivalent to ten percent of the total award at the time of actual payment. In line with the State’s policy to protect labor rights, the POEA-SEC is designed to benefit Filipino seafarers. Its provisions should be construed and applied fairly, reasonably, and liberally in their favor.

FAQs

What was the key issue in this case?	The key issue was whether a seafarer’s illness (rectosigmoid adenocarcinoma), not explicitly listed as an occupational disease under the POEA-SEC, is compensable due to work-related factors like diet and labor. The court also took up the issues on sickness allowance and attorney’s fees.
What is the POEA-SEC?	The POEA-SEC refers to the Philippine Overseas Employment Administration Standard Employment Contract for Seafarers, which sets the terms and conditions of employment for Filipino seafarers. It outlines the rights and obligations of both the seafarer and the employer.
What constitutes a work-related illness under the POEA-SEC?	A work-related illness is defined as any sickness resulting in disability or death as a result of an occupational disease listed under Section 32-A of the POEA-SEC, or any illness that can be proven to have been caused or aggravated by working conditions. Even illnesses not listed in Section 32-A can be compensable if proven to be work-related.
What evidence did Lagne present to support his claim?	Lagne presented evidence of his duties as an oiler, the food provisions on the ship, and medical assessments linking his condition to dietary factors and strenuous work conditions. He also presented a medical assessment from a private doctor stating that he was unfit to work as a seaman.
How did the Court interpret the POEA-SEC in favor of the seafarer?	The Court interpreted the POEA-SEC liberally, emphasizing that its provisions are designed to protect Filipino seafarers. It stated that even a small degree of contribution from employment to the development of a disease is sufficient for compensability.
What is the significance of the company-designated physician’s opinion?	While the opinion of the company-designated physician is considered, the Court also takes into account the findings of other medical professionals and the overall circumstances of the case. In this case, the Court gave more weight to the NLRC and CA findings, considering the factors of dietary provisions and working conditions.
What are the implications of this ruling for other seafarers?	This ruling reinforces the rights of seafarers to claim disability benefits for illnesses that are work-related, even if not explicitly listed as occupational diseases. It highlights the importance of considering the seafarer’s work environment and dietary conditions in assessing compensability.
What is sickness allowance, and how is it awarded?	Sickness allowance is a benefit provided to seafarers who are signed off from the vessel for medical treatment. It is equivalent to the seafarer’s basic wage and is paid until they are declared fit to work or the degree of permanent disability has been assessed, but not exceeding 120 days.
Why was attorney’s fees awarded in this case?	Attorney’s fees were awarded because Lagne was compelled to litigate to protect his rights due to the petitioners’ failure to satisfy his valid claim. This is in line with the principle that an employee forced to litigate is entitled to compensation for the expenses incurred.

In conclusion, the Supreme Court’s decision in Skippers United Pacific, Inc. v. Lagne underscores the importance of liberally interpreting the POEA-SEC to protect the rights of Filipino seafarers. It clarifies that even illnesses not explicitly listed as occupational diseases can be compensable if the working conditions contributed to their development or aggravation, ensuring that seafarers receive the benefits they are entitled to under the law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Skippers United Pacific, Inc. v. Lagne, G.R. No. 217036, August 20, 2018