The Supreme Court ruled that for a seafarer’s death to be compensable, it must be proven that the death was work-related and occurred during the employment contract. The burden of proof lies with the claimant to substantiate their claim with relevant evidence. This means that simply alleging a condition is work-related is insufficient; concrete evidence linking the illness to working conditions is required to receive death benefits.

Seafarer’s Renal Failure: Was It the Sea or a Silent Predisposition?

This case revolves around Alma Covita’s claim for death benefits after her husband, Rolando, passed away from chronic renal failure. Rolando was employed by SSM Maritime Services, Inc. as a Bosun. Although he was declared fit for duty during his pre-employment medical examination (PEME), he developed weakness and vomiting shortly after boarding his vessel. He was diagnosed with end-stage renal failure and medically repatriated, eventually passing away. Alma argued that Rolando’s condition was work-related, stemming from the stress and heavy workload inherent in his seafaring job. The respondents, however, contended that his illness was not work-related and developed over a long period, unrelated to his brief stint on the vessel. The central legal question is whether Alma successfully proved that Rolando’s chronic renal failure was causally linked to his work as a seafarer, entitling her and her children to death benefits.

The Supreme Court emphasized that while a seafarer’s employment is governed by the contract they sign, the POEA Standard Employment Contract is deemed written into it, setting minimum requirements for Filipino seafarers on foreign vessels. Section 20(A) of the 2000 POEA Standard Employment Contract outlines the conditions for death benefits. It explicitly states that the death must be work-related and occur during the term of the employment contract. Work-related death, as the court clarified, refers to death resulting from a work-related injury or illness. To be precise, Section 20(A) states:

SECTION 20. COMPENSATION AND BENEFITS

A. COMPENSATION AND BENEFITS FOR DEATH

1. In the case of work-related death of the seafarer during the term of his contract, the employer shall pay his beneficiaries the Philippine Currency equivalent to the amount of Fifty Thousand US dollars (US$50,000) and an additional amount of Seven Thousand US dollars (US$7,000) to each child under the age of twenty-one (21) but not exceeding four (4) children, at the exchange rate prevailing during the time of payment.

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4. The other liabilities of the employer when the seafarer dies as a result of work-related injury or illness during the term of employment are as follows:

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c. The employer shall pay the beneficiaries of the seafarer the Philippine currency equivalent to the amount of One Thousand US dollars (US$1,000) for burial expenses at the exchange rate prevailing during the time of payment.

Building on this principle, the Court then defined a work-related illness within the context of the POEA Standard Employment Contract. Any sickness resulting in disability or death due to an occupational disease listed under Section 32-A is considered work-related, provided certain conditions are met. These conditions include the seafarer’s work involving the described risks, the disease being contracted as a result of exposure to those risks, the disease being contracted within a specific exposure period, and the absence of notorious negligence on the seafarer’s part. While illnesses not listed in Section 32-A are disputably presumed work-related under Section 20B(4), this presumption does not relieve the claimant of the burden of proof. As the Supreme Court emphasized, Section 20 must be interpreted alongside the conditions specified in Section 32-A for an illness to be compensable.

The Court cited Quizora v. Denholm Crew Management (Phils.), Inc., highlighting that the disputable presumption does not allow the claimant to simply rely on it without substantiating their claim. The seafarer must prove that the illness was work-related and existed during the term of their employment contract. In Alma’s case, she argued that her husband’s chronic renal failure was caused by high blood pressure, which in turn was caused by the stress of his work as a seaman. The Court, however, found her allegations to be mere general statements without supporting evidence. She did not provide specific details about Rolando’s daily tasks, working conditions, or medical records demonstrating that his work aggravated his condition.

In essence, the Supreme Court highlighted the lack of concrete evidence linking Rolando’s kidney failure to his shipboard duties. The court emphasized that bare allegations of stress and heavy workload are insufficient to establish a causal connection. There was no record of Rolando suffering from high blood pressure during his brief period of employment on the vessel, which could have supported the claim that his work exacerbated his condition. The Court reiterated that self-serving allegations, without credible information, are inadequate to prove work-relatedness. The claimant must present evidence to prove a positive proposition. As the Court has previously ruled, the probability of work-connection must be anchored on credible information and not on unsubstantiated claims.

Furthermore, the Court addressed the timeline of Rolando’s illness. He was diagnosed with chronic renal failure after only seven days on board the vessel. The Court cited medical principles that chronic renal failure results from a progressive and irreversible destruction of nephrons over a period of time, making it highly improbable that it developed within such a short period. This point was also underscored with reference to Masangcay v. Trans-Global Maritime Agency, Inc., which stated that it is highly improbable that Masangcay’s chronic renal failure developed in just a month’s time.

In Harrison’s Principles of Internal Medicine, chronic renal failure is described as a result of progressive and irreversible destruction of nephrons, regardless of cause. This diagnosis implies that glomerular filtration rate (GFR) is known to have been reduced for at least 3 to 6 months. Often a gradual decline in GFR occurs over a period of years. It is, therefore, highly improbable that Masangcay’s chronic renal failure developed in just a month’s time, the length of time he was on board M/T Eastern Jewel before the symptoms became manifest.

The Court also clarified that Rolando’s employment was effectively terminated upon his medical repatriation, meaning his death did not occur during the term of his employment contract. The fact that Rolando had previous contracts with the same respondents was also addressed. The Court stated that each contract is separate and automatically terminates upon expiration. If Rolando had a pre-existing condition, his death arising from it is not compensable under his last employment contract, unless it can be proven that his working conditions during that specific contract aggravated the condition. In this case, there was no substantial evidence to prove that his job as a bosun had aggravated his illness. Also, the PEME results does not irrevocably prove that one is free from any ailment prior to deployment.

FAQs

What was the key issue in this case?	The key issue was whether the chronic renal failure that caused the seafarer’s death was work-related and occurred during his employment contract, entitling his beneficiaries to death benefits. The court examined the evidence to determine if there was a causal link between his work and his illness.
What is the significance of the POEA Standard Employment Contract in this case?	The POEA Standard Employment Contract governs the terms and conditions of employment for Filipino seafarers. It outlines the requirements for compensation and benefits, including death benefits, and defines what constitutes a work-related illness.
What is required to prove that an illness is work-related under the POEA contract?	To prove an illness is work-related, the claimant must present substantial evidence showing that the seafarer’s work involved risks associated with the illness, the disease was contracted due to exposure to those risks, and the disease manifested within a specific exposure period. Self-serving allegations will not suffice.
What is the effect of a pre-employment medical examination (PEME)?	A PEME is a summary examination of a seafarer’s physiological condition. A “fit to work” declaration in a PEME is not a conclusive proof that one is free from any ailment prior to his deployment.
What is the disputable presumption of work-relatedness?	Under Section 20B(4) of the POEA contract, illnesses not listed as occupational diseases are disputably presumed work-related. However, this presumption does not relieve the claimant of the burden of proving a causal link between the illness and the seafarer’s work.
Can a seafarer receive death benefits if they had a pre-existing condition?	If a seafarer had a pre-existing condition, their death arising from it is not compensable under their last employment contract. Unless it can be proven that the working conditions during that specific contract aggravated the condition.
What kind of evidence is needed to support a claim for death benefits?	To support a claim for death benefits, the claimant should provide specific evidence, such as medical records, detailed descriptions of the seafarer’s daily tasks and working conditions, and expert medical opinions linking the illness to the seafarer’s work.
How does the timing of the illness affect a claim for death benefits?	To be eligible for death benefits, the illness must be proven to have occurred or been aggravated during the term of the seafarer’s employment contract. The death must also occur during the term of the employment contract.

In conclusion, this case underscores the importance of providing concrete evidence to support claims for death benefits for seafarers. The burden of proof lies with the claimant to establish a clear causal link between the seafarer’s work and their illness. General allegations and unsubstantiated claims are insufficient to overcome this burden. This ruling serves as a reminder to meticulously document working conditions and gather relevant medical evidence to support claims for 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: ALMA COVITA v. SSM MARITIME SERVICES, INC., G.R. No. 206600, December 07, 2016