The Supreme Court has affirmed that a seafarer’s pre-existing health condition, known and acknowledged before employment, significantly impacts their ability to claim disability benefits. This ruling underscores the importance of transparency during pre-employment medical examinations (PEME) and the seafarer’s responsibility to comply with prescribed medical procedures. The court emphasized that while a seafarer’s work may aggravate a pre-existing condition, the burden of proof lies with the claimant to demonstrate a direct causal link between their work and the aggravation of their illness.

High Blood Pressure at Sea: When Does a Seafarer’s Condition Qualify for Disability Benefits?

Danilo Pacio, hired as an Able Seaman, disclosed his hypertension during his PEME. Despite this, he was declared fit but signed an undertaking acknowledging his condition and committing to medication. After five months at sea, he experienced high blood pressure and dizziness, leading to his repatriation and a diagnosis of hypertension and a transient ischemic attack (TIA). The company-designated physician deemed his condition not work-related, but Pacio later sought permanent total disability benefits, arguing his condition was work-aggravated. The legal question at the heart of the matter was whether Pacio’s pre-existing hypertension and subsequent TIA entitled him to disability benefits under the POEA Standard Employment Contract (SEC), especially considering his prior acknowledgment of the condition.

The case hinged on whether Pacio’s disability was work-related or aggravated by his employment, and whether he followed the proper procedures for claiming disability benefits. The Labor Arbiter (LA) initially ruled in favor of Pacio, awarding him US$60,000.00 in disability benefits plus attorney’s fees. The National Labor Relations Commission (NLRC) affirmed this decision. However, the Court of Appeals (CA) reversed the NLRC’s ruling, finding that the labor tribunals had gravely abused their discretion. The CA highlighted Pacio’s pre-existing condition, his acknowledgment of it, and his failure to comply with the prescribed procedures for disability compensation.

The Supreme Court, in reviewing the CA’s decision, emphasized that its role is generally limited to questions of law. However, it acknowledged an exception when the factual findings of lower tribunals contradict each other, as was the case here. Thus, the Court delved into the records to determine the validity of Pacio’s claim. The Court underscored the importance of the POEA SEC and relevant labor laws, which are deemed integrated into the employment contract. These provisions outline the process for claiming disability benefits and the criteria for determining disability.

Article 198 of the Labor Code defines total and permanent disabilities, including temporary total disability lasting more than 120 days and permanent complete paralysis of two limbs. Section 2, Rule X of the Amended Rules on Employees’ Compensation also stipulates the conditions for entitlement. Moreover, Section 20(B)(3) of the POEA SEC requires a seafarer to submit to a post-employment medical examination by a company-designated physician within three working days of repatriation. Failure to comply with this requirement forfeits the right to claim benefits.

The Court found that Pacio failed to comply with this statutory process, despite the respondents’ efforts to facilitate it. The company-designated physician provided an assessment of Pacio’s illness within the allotted time, contrary to Pacio’s claim. “Laboratory examination showed decreased hemoglobin, hematocrit, white blood cell (complete blood count), normal fasting blood sugar, HBA1C, blood urea nitrogen, creatinine, triglyceride, HDL, thyroid function test, VLDL, SGPT, sodium, potassium, urinalysis, elevated uric acid, cholesterol, LDL and creatine kinase.” The report also stated, “The etiology/cause of hypertension is not work-related. It is multifactorial in origin, which includes generic predisposition, poor lifestyle, high salt intake, smoking, Diabetes Mellitus, age and increased sympathetic activity.”

Furthermore, Pacio refused to return for further tests and spent nearly a year out of contact with the respondents before filing his complaint. The Court found this lack of cooperation and the belated filing of the claim indicative of bad faith.

“Ruizo’s non-compliance with his obligation under the POEA-SEC is aggravated by the fact that while he was still undergoing treatment under the care of Dr. Cruz, he filed the present complaint on May 26, 2006.” (Splash Philippines, Inc., et al. v. Ruizo, 730 Phil. 162 (2014))

Thus, his refusal to cooperate not only made his claim questionable but also vitiated the validity of his own assertions.

The POEA SEC provides a mechanism for resolving disputes in medical findings:

“Under Section 20(A)(3) of the 2010 POEA SEC, if a doctor appointed by the seafarer disagrees with the assessment, a third doctor may be agreed jointly between the Employer and the seafarer, whose decision shall be final and binding on both parties.”

Pacio did not avail himself of this remedy, filing his complaint without informing the respondents of his physician’s contrary findings. The Court emphasized the seafarer’s duty to actively request the opinion of a third doctor when medical findings diverge.

Even more, the Court emphasized Pacio’s failure to provide substantial evidence that his condition was aggravated by his work. While the law recognizes a disputable presumption of work-relatedness, the seafarer must still demonstrate a reasonable connection between the nature of their work and their illness. Pacio’s reliance on the presumption without presenting substantial evidence of causation proved detrimental to his claim. The Court highlighted that if a heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain brought about by the nature of his work, quoting the case Villanueva, Sr. v. Baliwag Navigation, Inc., et al., 715 Phil. 299 (2013).

FAQs

What was the key issue in this case?	The key issue was whether a seafarer with a pre-existing condition, who acknowledged it prior to employment, is entitled to disability benefits when that condition allegedly worsens during their employment.
What is a Pre-Employment Medical Examination (PEME)?	A PEME is a medical assessment conducted before employment to determine an individual’s fitness for the job. It helps employers understand any pre-existing conditions that may affect the employee’s ability to perform their duties.
What is the role of the company-designated physician?	The company-designated physician is responsible for assessing the seafarer’s medical condition and determining whether it is work-related or if the seafarer is fit to work. Their assessment is crucial for determining eligibility for disability benefits.
What is the significance of the POEA Standard Employment Contract (SEC)?	The POEA SEC sets the terms and conditions of employment for Filipino seafarers, including provisions for disability benefits, medical examinations, and dispute resolution. It is deemed integrated into the employment contract between the seafarer and the employer.
What happens if the seafarer disagrees with the company-designated physician’s assessment?	The POEA SEC provides a mechanism for resolving disputes: A third doctor may be agreed upon by both the employer and the seafarer, whose decision shall be final and binding. The seafarer must actively request a third opinion.
What evidence is needed to prove a condition is work-related?	The seafarer must provide substantial evidence showing a reasonable connection between the nature of their work and the illness contracted or aggravated. This may include medical records, witness testimonies, and expert opinions.
What is the impact of signing an undertaking acknowledging a pre-existing condition?	Signing an undertaking acknowledging a pre-existing condition can make it more difficult for the seafarer to claim disability benefits for that condition. However, it does not completely bar a claim if the seafarer can prove that their work aggravated the condition.
What are the key steps a seafarer should take if they believe their condition is work-related?	The seafarer should promptly report their condition to the employer, submit to a medical examination by the company-designated physician, actively participate in the assessment process, and seek a third opinion if they disagree with the initial assessment.

This case serves as a reminder of the importance of transparency, cooperation, and adherence to prescribed procedures in seafarer disability claims. The burden of proof lies with the claimant to demonstrate a direct link between their work and the aggravation of their illness. Seafarers with pre-existing conditions should be particularly diligent in documenting their medical history and following the proper channels for seeking medical assistance and compensation.

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: DANILO L. PACIO v. DOHLE-PHILMAN MANNING AGENCY, INC., G.R. No. 225847, July 03, 2019