The Supreme Court has ruled that seafarers who deliberately conceal pre-existing medical conditions during their pre-employment medical examinations (PEME) are not entitled to disability benefits if those conditions later cause disability. This decision underscores the importance of honesty and full disclosure in maritime employment. Seafarers are now on notice that any attempt to deceive their employers about their health status can have serious consequences, potentially disqualifying them from receiving compensation for work-related illnesses or injuries.

Seafarer’s Stroke: Was It Work-Related or a Hidden Health Risk?

The case of Antonio B. Manansala v. Marlow Navigation Phils., Inc. revolves around a seafarer, Antonio B. Manansala, who suffered a stroke while working on board a vessel. Manansala sought total and permanent disability benefits from his employer, Marlow Navigation. However, the company denied his claim, alleging that Manansala had failed to disclose pre-existing conditions of hypertension and diabetes during his pre-employment medical examination (PEME). The central legal question before the Supreme Court was whether Manansala’s disability was compensable, considering his failure to disclose his pre-existing conditions.

Before his deployment, Manansala underwent a PEME where he explicitly denied having hypertension and diabetes. On May 30, 2010, while on board the M/V Seaboxer, Manansala suffered a stroke, leading to his repatriation. He was subsequently assessed by a company-designated physician, Dr. Teresita Barrairo, and later sought a medical opinion from his own doctor, Dr. Amado San Luis. Dr. San Luis’s evaluation revealed that Manansala admitted to a long history of hypertension and diabetes, even taking medication for these conditions.

The Labor Arbiter, the National Labor Relations Commission (NLRC), and the Court of Appeals all ruled against Manansala, finding that his disability stemmed from pre-existing conditions that he had fraudulently concealed. This prompted Manansala to elevate the case to the Supreme Court, arguing that he had properly disclosed his pre-existing illnesses and that his stroke was work-related. The Supreme Court, however, was not persuaded.

The Court emphasized that seafarers are contractual employees whose employment is governed by their contracts and the POEA Standard Employment Contract (POEA-SEC). The POEA-SEC mandates employers to compensate seafarers for work-related illnesses. It defines a work-related illness as any sickness resulting in disability or death as a result of an occupational disease. For an occupational disease to be compensable, it must be directly linked to the seafarer’s work and working conditions.

The Court acknowledged that pre-existing illnesses could be aggravated by a seafarer’s working conditions, making them compensable to the extent of the aggravation. However, it also highlighted Section 20(E) of the POEA-SEC, which explicitly disqualifies a seafarer from receiving compensation if they knowingly conceal a past medical condition during the PEME. The crucial aspect here is the element of fraudulent misrepresentation, requiring not just falsity but a deliberate intent to deceive for personal gain. “A seafarer who knowingly conceals and does not disclose past medical condition, disability and history in the pre-employment medical examination constitutes fraudulent misrepresentation and shall disqualify him from any compensation and benefits.”

The Court delved into the nature of PEMEs, noting that they involve both the seafarer’s self-assessment and medical professionals’ evaluations. While seafarers may not fully understand the nuances of their medical conditions, they are expected to provide honest and accurate information. The Court noted, “As laypersons, seafarers cannot be expected to make completely accurate accounts of their state of health. Unaware of the nuances of medical conditions, they may, in good faith, make statements that turn out to be false. These honest mistakes do not negate compensability for disability arising from pre-existing illnesses shown to be aggravated by their working conditions. However, when a seafarer’s proper knowledge of pre-existing conditions and intent to deceive an employer are established, compensability is negated.”

In Manansala’s case, the Supreme Court found clear evidence of fraudulent misrepresentation. He had denied having hypertension and diabetes during his PEME and to the company-designated physician. However, he later admitted to his own doctor that he had a long history of these conditions and was taking medication for them. Manansala’s attempt to blame the examining physician for inaccurately recording his responses was viewed as an admission of his knowledge of the conditions at the time of the examination.

The Court emphasized that Manansala, being an experienced seafarer, understood the significance of truthful declarations during the PEME. His failure to rectify the alleged error in his examination certificate and his subsequent denials to the company-designated physician further undermined his credibility. The court stated: “Petitioner’s assertion is an admission that he fully knew of his conditions at the moment he was examined, rendering it pointless for this Court to consider whether he was merely confused at the time of his examination. Additionally, his assertion burdens him with the task of proving his claims.”

Furthermore, the Court noted Manansala’s failure to comply with the POEA-SEC’s procedure for resolving disputes regarding disability assessments. Section 20(B)(3) of the POEA-SEC mandates referral to a third physician if the seafarer’s doctor disagrees with the company-designated physician’s assessment. Manansala did not initiate this process, further weakening his claim. Thus the Court held: “If a doctor appointed by the seafarer disagrees with the assessment, a third doctor may be agreed jointly between the Employer and the seafarer. The third doctor’s decision shall be final and binding on both parties.”

Ultimately, the Supreme Court upheld the Court of Appeals’ decision, denying Manansala’s claim for disability benefits. The Court concluded that Manansala had engaged in “serial dishonesty” and was therefore disqualified from receiving compensation under Section 20(E) of the POEA-SEC. This case serves as a reminder of the importance of honesty and transparency in maritime employment, particularly concerning pre-existing medical conditions. Seafarers must be truthful about their health status to ensure they are fit for duty and to avoid forfeiting their right to compensation should they become disabled.

FAQs

What was the key issue in this case?	The key issue was whether a seafarer was entitled to disability benefits when he failed to disclose pre-existing medical conditions during his pre-employment medical examination (PEME).
What is a PEME and why is it important?	A PEME is a pre-employment medical examination required for seafarers to determine their fitness for work. It’s important because it ensures that seafarers are healthy enough to perform their duties and protects employers from liability for pre-existing conditions.
What does the POEA-SEC say about concealing medical conditions?	Section 20(E) of the POEA-SEC states that a seafarer who knowingly conceals a past medical condition during the PEME is disqualified from receiving compensation and benefits. This is considered fraudulent misrepresentation.
What is considered a work-related illness under the POEA-SEC?	A work-related illness is any sickness resulting in disability or death as a result of an occupational disease listed under Section 32-A of the POEA-SEC. The conditions set therein must also be satisfied.
What should a seafarer do if they disagree with the company doctor’s assessment?	If a seafarer disagrees with the company-designated physician’s assessment, they can request a third doctor to be jointly agreed upon by the employer and the seafarer. The third doctor’s decision shall be final and binding on both parties.
What evidence did the court use to determine fraudulent misrepresentation?	The court relied on the seafarer’s conflicting statements: denying hypertension and diabetes during the PEME but later admitting to his own doctor that he had a history of these conditions and was taking medication.
Can a seafarer get disability benefits if a pre-existing condition is aggravated by work?	Yes, a seafarer may be entitled to disability benefits if a pre-existing condition is aggravated by their working conditions. However, the seafarer must not have fraudulently concealed the condition during the PEME.
What happens if a seafarer makes an honest mistake about their medical history?	If a seafarer makes an honest mistake or is unaware of the nuances of their medical condition, it may not negate compensability. The key factor is whether there was a deliberate intent to deceive the employer.

This case highlights the critical importance of honesty during pre-employment medical examinations for seafarers. By upholding the POEA-SEC provisions on fraudulent misrepresentation, the Supreme Court has reinforced the need for transparency and accountability in maritime employment. This ruling impacts not only seafarers but also employers, ensuring a fair and equitable system for disability 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: ANTONIO B. MANANSALA VS. MARLOW NAVIGATION PHILS., INC., G.R. No. 208314, August 23, 2017