The Supreme Court has affirmed that cardiovascular diseases suffered by seafarers can be considered work-related and thus compensable, even if not explicitly listed as occupational diseases. This decision reinforces the principle that the strenuous nature of a seafarer’s work, coupled with prolonged service, can significantly contribute to the development of such conditions, entitling them to disability benefits. This ruling highlights the importance of considering the unique challenges and stresses faced by seafarers in assessing claims for work-related illnesses.

From Third Mate to Patient: Can Years at Sea Cause a Compensable Heart Condition?

Juanito Bengson, a seafarer for Magsaysay Mitsui OSK Marine, Inc., experienced difficulty breathing and numbness while working as a Third Mate. He was diagnosed with a small hematoma in the brain and other conditions like stroke and hypertension. While the company-designated physician initially deemed his illness not work-related, Bengson argued that his long years of service and the stressful nature of his job contributed to his condition. The central legal question was whether Bengson’s cardiovascular disease was indeed work-related, thus entitling him to disability benefits under his employment contract and Philippine law. This case navigated the complexities of proving the causal link between a seafarer’s work environment and the onset of a critical illness.

The Labor Arbiter initially ruled in favor of Bengson, citing the strenuous nature of his work and the conditions on board the vessel as contributing factors to his illness. However, the National Labor Relations Commission (NLRC) reversed this decision, arguing that hematoma was not a listed compensable illness under the POEA-SEC and that Bengson failed to prove a direct link to his work. The Court of Appeals (CA) then overturned the NLRC decision, finding that Bengson’s exposure to hazards, the demands of his position, and the physical and mental strain he endured contributed to his condition. The CA awarded him disability benefits, recognizing his illness as work-related under the POEA-SEC.

The Supreme Court, in its analysis, delved into the established jurisprudence concerning cardiovascular diseases and their compensability in the context of seafarers’ employment. Citing numerous precedents, the Court highlighted that cardiovascular disease, coronary artery disease, and other heart ailments are often deemed compensable due to the inherent stresses and demands of maritime work. These cases underscore a recognition that the unique pressures faced by seafarers—including long hours, separation from family, and exposure to hazardous conditions—can significantly contribute to the development or aggravation of heart-related conditions.

The petitioners argued that the company-designated physician’s assessment, stating that Bengson’s illness was not work-related, should prevail. They contended that Bengson had not presented sufficient evidence to demonstrate a direct causal link between his work and his condition. However, the Court gave weight to the undisputed facts of Bengson’s long service, his responsibilities as Third Mate, and the inherent stresses associated with his position. It emphasized that as Third Mate, Bengson was responsible for navigation, ship safety, and emergency management, all of which placed him under considerable physical and mental strain. The Court reasoned that these factors, combined with the prolonged duration of his employment, contributed to the development of his hypertensive cardio-vascular disease.

Furthermore, the Court addressed the argument that Bengson’s illness was not explicitly listed as an occupational disease under the POEA-SEC. Citing established jurisprudence, the Court clarified that the POEA-SEC list is not exhaustive and does not preclude other illnesses from being deemed compensable if a causal link to the employment can be established. As emphasized in Fil-Pride Shipping Company, Inc. v. Balasta, “the list of illnesses/diseases in Section 32-A does not preclude other illnesses/diseases not so listed from being compensable. The POEA-SEC cannot be presumed to contain all the possible injuries that render a seafarer unfit for further sea duties.” This principle underscores the importance of a case-by-case analysis to determine the compensability of illnesses not explicitly listed in the POEA-SEC.

The Court also considered the significance of the company-designated physician’s failure to provide a definitive assessment of Bengson’s fitness or disability. As established in Alpha Ship Management Corporation v. Calo, an employee’s disability becomes permanent and total when the company-designated physician fails to issue a declaration of fitness or disability within the prescribed period. In Bengson’s case, despite undergoing treatment and rehabilitation, the company-designated physician did not provide a conclusive assessment, leaving Bengson’s medical condition unresolved. Given the serious nature of his illness and his inability to return to work, the Court concluded that Bengson was entitled to permanent and total disability benefits under the POEA-SEC.

In its ruling, the Court affirmed the CA’s decision but modified the award, specifying that the disability benefits and attorney’s fees should be paid in Philippine pesos, computed at the exchange rate prevailing at the time of payment. The Court’s decision reinforces the principle that seafarers are entitled to compensation for work-related illnesses, even if not explicitly listed, and emphasizes the importance of considering the totality of their work experience and the impact on their health. This ruling serves as a crucial precedent for future cases involving seafarers’ claims for disability benefits due to cardiovascular diseases and other work-related ailments. The Court’s decision ensures that seafarers are adequately protected and compensated for the risks and sacrifices inherent in their profession.

FAQs

What was the key issue in this case?	The central issue was whether Juanito Bengson’s cardiovascular disease was work-related, entitling him to disability benefits despite the company physician’s initial assessment. The court examined the connection between his long years of service as a seafarer and the development of his condition.
What was the Supreme Court’s ruling?	The Supreme Court affirmed that Bengson’s cardiovascular disease was indeed work-related and compensable, upholding the Court of Appeals’ decision with a modification on the currency of payment. This reinforces the principle that seafarers can receive compensation for illnesses stemming from the stresses of their work.
What is the significance of the POEA-SEC in this case?	The POEA-SEC lists occupational diseases, but the Court clarified that the list isn’t exhaustive. Illnesses not explicitly listed can still be compensable if a direct link to the seafarer’s employment is proven, as was the case with Bengson’s cardiovascular disease.
What factors did the Court consider in determining if the illness was work-related?	The Court considered Bengson’s long years of service, the demanding nature of his role as Third Mate, and the inherent stresses of maritime work. These factors, combined with the absence of a conclusive assessment from the company physician, supported the conclusion that his illness was work-related.
What is the role of the company-designated physician’s assessment?	While the company-designated physician’s assessment is important, it’s not the sole determinant. The Court considered the physician’s failure to provide a definitive assessment of Bengson’s fitness, combined with other evidence, in reaching its decision.
What does this case mean for other seafarers with similar conditions?	This case sets a precedent for seafarers suffering from cardiovascular diseases, making it clear that such conditions can be deemed work-related. It emphasizes the importance of considering the cumulative impact of a seafarer’s work on their health.
How did the Court address the lack of a specific listing for Bengson’s illness in the POEA-SEC?	The Court emphasized that the POEA-SEC’s list of occupational diseases is not exhaustive. It stated that other illnesses can be compensable if a causal link to the seafarer’s employment can be established, which was demonstrated in Bengson’s case.
What was the final award granted to Bengson?	The Court affirmed the award of US$60,000.00 in disability benefits and attorney’s fees, with the modification that the payment should be made in Philippine pesos based on the exchange rate at the time of payment. This ensured Bengson received appropriate compensation for his permanent and total disability.

This landmark decision underscores the Philippine legal system’s commitment to protecting the rights and welfare of seafarers, acknowledging the unique health challenges they face due to the demanding nature of their profession. By recognizing the compensability of cardiovascular diseases under specific circumstances, the Supreme Court has provided a significant legal precedent for future claims, ensuring that seafarers receive the support and benefits they deserve.

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: MAGSAYSAY MITSUI OSK MARINE, INC. VS. JUANITO G. BENGSON, G.R. No. 198528, October 13, 2014