The Supreme Court ruled that a seafarer’s claim for disability benefits due to illness requires substantial evidence establishing a direct link between the illness and the conditions of their work. In this case, the Court found that the seafarer failed to prove that his stomach cancer was caused or aggravated by his duties as a chief cook. This decision emphasizes the importance of demonstrating a clear causal relationship between a seafarer’s work and their illness to successfully claim disability benefits.

Gastric Cancer at Sea: Proving the Link Between a Cook’s Work and His Illness

Demetrio Aligway, Jr., a chief cook employed by Philippine Transmarine Carriers, Inc. (PTC), filed a complaint for disability benefits, claiming his gastric cancer was work-related. He argued that his work, involving food intake, contributed to or aggravated his condition. PTC countered that Demetrio was a heavy smoker and that his condition was not work-related, citing a medical report from their designated physician. The Labor Arbiter (LA) dismissed Demetrio’s complaint, a decision affirmed by the National Labor Relations Commission (NLRC). However, the Court of Appeals (CA) reversed these rulings, granting Demetrio full disability benefits. This led to PTC appealing to the Supreme Court, questioning whether the CA erred in finding grave abuse of discretion on the part of the NLRC.

The Supreme Court emphasized that while it generally reviews only questions of law, an exception exists when lower courts’ factual findings conflict. In this case, the LA and NLRC found no entitlement to disability benefits, while the CA ruled in favor of Demetrio. This discrepancy necessitated the Court’s own evaluation of the evidence. The Court reiterated that entitlement to disability benefits for seafarers is governed by medical findings, relevant laws, and the employment contract. Specifically, Articles 191 to 193 of the Labor Code, the POEA-SEC, and any applicable Collective Bargaining Agreement (CBA) define the scope and conditions of such benefits.

The Court highlighted the importance of establishing a work-related injury or illness, stating, “Under Section 20(B) of the 2000 POEA SEC, for disability to be compensable, (1) the seafarer’s injury or illness must be work-related; and (2) the work-related injury or illness must have existed during the term of his employment contract.” This section underscores that a seafarer must prove both the existence of a disability and a causal link between the disability and their work. The burden of proof rests on the seafarer to demonstrate this causal relationship through substantial evidence. Substantial evidence is defined as “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”

In Demetrio’s case, the Supreme Court found that he failed to meet this burden. He did not adequately prove that his stomach cancer was causally connected to his work as a chief cook. Demetrio’s argument rested on the speculation that smoked food might promote the development of stomach cancer and that his work involved food intake, which allegedly contributed to his illness. The Court considered these statements as self-serving allegations that lacked concrete evidence. Even if the claim were based on the probability of work-relatedness, such probability must be anchored on credible information, not merely on the seafarer’s assertions.

Furthermore, the Court dismissed the argument that passing the pre-employment medical examination (PEME) automatically implied that Demetrio acquired his illness on board the vessel. The Court clarified that “The PEME conducted upon a seafarer would not or could not necessarily reveal or disclose his illness because such examination is not at all fool-proof or thoroughly exploratory.” The PEME serves a limited purpose and cannot guarantee the absence of any underlying conditions. This point emphasizes the need for seafarers to present additional evidence to support their claims beyond simply having passed the PEME.

The medical report from the company-designated physician, Dr. Salvador, played a significant role in the Court’s decision. Dr. Salvador stated that Demetrio’s condition was not work-related or work-aggravated. Her report listed various potential causes of stomach cancer, including diet, environmental factors, chronic gastritis, genetic factors, H. pylori infection, previous gastric surgery, obesity, and radiation exposure. The Court emphasized that in the absence of a second opinion from Demetrio’s own physician, it could not arbitrarily disregard the findings of the company-designated doctor. This highlights the importance of seeking independent medical evaluations to challenge the findings of company-designated physicians.

The Supreme Court emphasized the significance of the company-designated doctor’s medical opinion, noting that the seafarer bears the responsibility of presenting substantial evidence that establishes a medically-recognized connection between their work and the ailment they are suffering from. The Court thus sided with the NLRC’s decision, affirming the Labor Arbiter’s initial dismissal of the claim, effectively reversing the Court of Appeals’ ruling. The Court made it clear that the claim was not substantiated by the necessary evidence.

FAQs

What was the key issue in this case?	The central issue was whether the seafarer’s gastric cancer was work-related, entitling him to disability benefits. The court examined the causal connection between his work as a chief cook and the development or aggravation of his illness.
What did the company-designated physician’s report state?	The company-designated physician, Dr. Salvador, concluded that Demetrio’s gastric cancer was not work-related or work-aggravated. She cited multiple potential causes of stomach cancer, including diet, environmental factors, and genetics.
What is the significance of the PEME in this case?	The court clarified that passing the pre-employment medical examination (PEME) does not guarantee the absence of pre-existing conditions or automatically imply that an illness was contracted during employment. The PEME serves a limited purpose and does not preclude the need for further evidence.
What is the burden of proof in disability claims for seafarers?	The burden of proof lies with the seafarer to demonstrate a causal connection between their illness and their work. This requires presenting substantial evidence that a reasonable person would accept as adequate to support the claim.
What constitutes substantial evidence in these cases?	Substantial evidence includes credible medical reports, expert testimony, and other relevant documentation that supports the claim that the seafarer’s work caused or aggravated their illness. Self-serving allegations and mere speculation are insufficient.
What happens if there is no second medical opinion?	The Court noted that in the absence of a second opinion from the seafarer’s chosen physician, the findings of the company-designated doctor generally prevail, unless there is clear evidence of bias or negligence. This reinforces the importance of seeking independent medical evaluations.
What is the role of the POEA-SEC in disability claims?	The POEA-SEC (Philippine Overseas Employment Administration Standard Employment Contract) sets the framework for seafarers’ employment terms, including provisions for disability benefits. Section 20(B) outlines the conditions for compensability, emphasizing the need for a work-related injury or illness during the contract term.
What are the implications for future seafarer disability claims?	This ruling underscores the importance of establishing a clear causal link between a seafarer’s work and their illness when filing for disability benefits. Seafarers should gather comprehensive medical evidence and seek independent medical evaluations to support their claims.

This case clarifies the standard of proof required for seafarers seeking disability benefits, emphasizing the necessity of establishing a direct causal link between their illness and their working conditions. The Supreme Court’s decision reinforces the importance of thorough medical evaluations and the presentation of substantial evidence to support such claims.

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: PHILIPPINE TRANSMARINE CARRIERS, INC. vs. JULIA T. ALIGWAY, G.R. No. 201793, September 16, 2015