In Transocean Ship Management (Phils.), Inc. v. Vedad, the Supreme Court ruled that a seafarer is entitled to sickness allowance even if the illness is later determined to be non-work-related, as long as the illness manifested during the employment period and repatriation occurred for medical reasons. This ensures seafarers receive financial support while awaiting medical assessments, reinforcing the protection afforded to them under the POEA-SEC. This decision highlights the importance of immediate assistance to seafarers who fall ill while serving on vessels, emphasizing the balance between employer responsibilities and seafarer’s welfare.

Navigating the High Seas of Health: When Can Seafarers Claim Sickness Benefits?

Inocencio Vedad, a seafarer, sought disability benefits and sickness allowance after being repatriated due to illness. He later developed cancer and was declared not work-related by the company-designated physician. Despite this, he argued he was entitled to sickness allowance for the period he was unable to work following his repatriation. The core legal question was whether a seafarer is entitled to sickness allowance when the illness manifests during employment but is later declared non-work-related.

The Supreme Court navigated through the provisions of the POEA-SEC (Philippine Overseas Employment Administration-Standard Employment Contract) to address this issue. The POEA-SEC is designed to protect Filipino seafarers working on international vessels. Section 20(B)(3) of the POEA-SEC is particularly relevant, stating that a seafarer is entitled to sickness allowance equivalent to his basic wage from the time of sign-off for medical treatment until declared fit to work or until the degree of permanent disability is assessed, but not exceeding 120 days.

The court emphasized the importance of providing immediate support to seafarers who fall ill during their employment. The entitlement to sickness allowance arises when the illness manifests during the period of employment, and repatriation occurs for medical reasons, regardless of the later determination of work-relatedness. This interpretation aligns with the POEA’s mandate to protect the welfare of Filipino workers overseas. The court also considered Section 20(B)(4) which stipulates that illnesses not listed in Section 32 of the contract are disputably presumed as work-related.

The court quoted key provisions of the POEA-SEC:

SECTION 20. COMPENSATION AND BENEFITS

B. COMPENSATION AND BENEFITS FOR INJURY OR ILLNESS

3. 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 this period exceed one hundred twenty (120) days.

The Supreme Court discussed the dual nature of claims by the seafarer: claims for sickness allowance versus claims for permanent total disability benefits. The court ruled that while Inocencio was entitled to sickness allowance, he was not entitled to permanent total disability benefits because he failed to prove his illness was work-related. This distinction is vital because the requirements for each claim differ significantly.

The court referenced Crystal Shipping, Inc. v. Natividad to support its decision, reinforcing the purpose of sickness allowance. As it states:

…an award of sickness allowance to Inocencio would be germane to the purpose of the benefit, which is to help the seafarer in making ends meet at the time when he is unable to work.

The court highlighted that the law favors laborers, and any ambiguity should be resolved in their favor. When evidence can be interpreted in two ways, one prejudicial and the other favorable, the favorable interpretation must prevail.

The court also addressed the employer’s promise to shoulder Inocencio’s medical expenses. Since Transocean had agreed to cover the medical costs, they were obligated to fulfill that commitment. The court found that Transocean’s failure to continue payments was unjustified, leading to the imposition of interest on the outstanding medical expenses and sickness allowance.

Regarding Inocencio’s failure to seek a second opinion from a physician of his choice, the Court stated:

Inocencio, however, failed to seek a second opinion from a physician of his choice. As already mentioned, Inocencio did not present any proof of work-relatedness other than his bare allegations. We, thus, have no option but to declare that the company-designated doctor’s certification is the final determination that must prevail.

This emphasizes the importance of seafarers seeking additional medical opinions to substantiate their claims.

FAQs

What was the key issue in this case?	The central issue was whether a seafarer is entitled to sickness allowance under the POEA-SEC when the illness manifests during employment but is later determined to be non-work-related. The Supreme Court ruled in favor of the seafarer, affirming the right to sickness allowance in such cases.
What is the POEA-SEC?	The Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) governs the employment of Filipino seafarers. It outlines the rights and obligations of both the seafarer and the employer, providing a framework for fair labor practices.
What does Section 20(B)(3) of the POEA-SEC state?	Section 20(B)(3) entitles a seafarer to sickness allowance equivalent to their basic wage from the time they sign off the vessel for medical treatment. This allowance continues until they are declared fit to work or the degree of permanent disability has been assessed, but it does not exceed 120 days.
Why was Inocencio Vedad entitled to sickness allowance?	Inocencio was entitled to sickness allowance because he became ill while under contract and was repatriated for medical reasons. Even though his illness was later declared non-work-related, the court upheld his right to the allowance.
What is the significance of the company-designated physician’s assessment?	The assessment of the company-designated physician is crucial in determining work-relatedness. If the seafarer disagrees with the assessment, they have the right to seek a second opinion from a physician of their choice.
What are the implications for employers based on this ruling?	Employers must provide sickness allowance to seafarers who become ill during their employment, regardless of a later determination of non-work-relatedness. They must also honor any commitments made regarding medical expenses.
What is the role of the National Labor Relations Commission (NLRC) in these cases?	The NLRC reviews decisions made by the Labor Arbiter. In this case, the NLRC initially reversed the Labor Arbiter’s decision but was later modified by the Court of Appeals and ultimately reversed by the Supreme Court.
What is the effect of failing to seek a second medical opinion?	Failing to seek a second medical opinion can weaken a seafarer’s claim, especially regarding permanent total disability benefits. The company-designated doctor’s assessment may then prevail.
Can a seafarer claim both sickness allowance and disability benefits?	A seafarer can claim both sickness allowance and disability benefits, but the requirements differ. Sickness allowance is granted if the illness manifests during employment, while disability benefits require proof that the illness is work-related.

The Supreme Court’s decision in Transocean Ship Management (Phils.), Inc. v. Vedad reinforces the protection for seafarers, ensuring they receive necessary financial support when illness strikes during their service. The case clarifies the entitlement to sickness allowance and the responsibilities of employers to uphold the welfare of their seafaring employees. This decision serves as a reminder of the importance of adhering to the standards set forth in the POEA-SEC, providing a safety net for those who dedicate their lives to maritime work.

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: TRANSOCEAN SHIP MANAGEMENT (PHILS.), INC. v. VEDAD, G.R. Nos. 194518 & 194524, March 20, 2013