This Supreme Court decision clarifies the rights of seafarers to disability benefits under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC). The court ruled that a seafarer, Melchor Barcenas Deocariza, was entitled to disability benefits because his employer failed to prove that he concealed a pre-existing heart condition. Additionally, the court found that Deocariza’s illness, aplastic anemia, was work-related due to his exposure to benzene on the job, and his disability claim was filed after the 240-day period without a definitive assessment. This case underscores the importance of full disclosure by seafarers and the employer’s responsibility to prove concealment and conduct timely medical assessments.

A Seafarer’s Aplastic Anemia: Did Exposure or Non-Disclosure Determine Disability Benefits?

This case revolves around Melchor Barcenas Deocariza, a Chief Officer on a vessel, who sought total and permanent disability benefits after being diagnosed with aplastic anemia. Deocariza filed a complaint against his employers, Fleet Management Services Philippines, Inc., Modern Asia Shipping Corporation, and their officers, claiming his illness rendered him unable to work. The central legal issue was whether Deocariza was entitled to disability benefits under the POEA-SEC, considering his illness and an alleged concealment of a pre-existing heart condition during his pre-employment medical examination (PEME).

The respondents argued that Deocariza knowingly concealed having “mechanical heart valves,” which they claimed would have disqualified him from employment. They also contended that his aplastic anemia was not work-related, asserting that his exposure to benzene, a component of gasoline from the cars loaded onto the vessel, was minimal and insufficient to cause the illness. Building on this assertion, the Labor Arbiter (LA) initially dismissed Deocariza’s complaint, a decision later affirmed by the National Labor Relations Commission (NLRC). The NLRC further emphasized the alleged concealment of his heart condition, which they deemed a disqualifying factor under the POEA-SEC and the Collective Bargaining Agreement (CBA). However, the Court of Appeals (CA) also sided with the NLRC, finding that Deocariza failed to prove his illness was work-related and that he concealed his artificial heart during his PEME, thus barring him from claiming disability benefits.

However, the Supreme Court reversed the CA’s decision, finding it based on speculation and misapprehension of facts. The court emphasized that under Section 20 (E) of the 2010 POEA-SEC, the burden of proof lies with the employer to demonstrate that the seafarer willfully concealed a pre-existing condition. An illness is considered pre-existing if, before the POEA contract processing, the seafarer had either been advised by a doctor on treatment for the condition or had knowledge of the illness but failed to disclose it during the PEME, and it was undetectable during the PEME. This means the employer must present substantial evidence of concealment and pre-existing condition.

In this instance, the court found insufficient evidence to support the claim that Deocariza had mechanical heart valves. While a foreign doctor in Singapore declared he had mechanical heart valves, this was not confirmed by the company-designated physician. Furthermore, Deocariza’s attending physician at Metropolitan Medical Center (MMC) certified that he never underwent heart surgery, his heart was in good condition, and his x-ray and 2D echocardiogram did not show mechanical heart valves. This certification was presented before the CA and was not challenged by the respondents. Based on this evidence, the Supreme Court concluded that the allegation of concealment was baseless, and the lower courts erred in upholding it.

The Supreme Court also addressed whether Deocariza’s aplastic anemia was work-related. Section 20 (A) of the 2010 POEA-SEC provides that a seafarer is entitled to compensation for work-related injuries or illnesses during their contract. A work-related illness includes any sickness resulting from an occupational disease listed under Section 32-A of the contract. The court noted that aplastic anemia is listed as an occupational disease under Sub-Item Number 7 of Section 32-A, specifically “anemia of the aplastic type due to x-rays, ionizing particle, radium or other radioactive substances.” In line with the company-designated physician’s findings that exposure to benzene could predispose one to this condition, the court analyzed Deocariza’s working conditions. Deocariza, as Chief Officer, actively supervised the loading and unloading of cars/motor vehicles, which exposed him to benzene emissions from the engines. Despite the use of safety gear, the court recognized that consistent exposure to benzene made his illness work-related.

Building on this, the court also considered the timeline of Deocariza’s medical assessment. Under Section 20 (A) of the 2010 POEA-SEC, the company-designated physician must make a definitive assessment of the seafarer’s fitness or degree of disability within 120 days from repatriation. This period can be extended up to 240 days if further medical attention is needed. If the physician fails to provide a definitive assessment within this timeframe, the seafarer is presumed totally and permanently disabled. From Deocariza’s repatriation on December 26, 2011, 247 days passed before his last consultation with the company-designated physician on August 29, 2012, with no definitive assessment. Therefore, the Supreme Court concluded that Deocariza was conclusively presumed totally and permanently disabled.

Finally, the court addressed the issue of compensation. Deocariza claimed benefits under the CBA, but the court found he was entitled to total and permanent disability benefits under the 2010 POEA-SEC. According to Section 32 of the 2010 POEA-SEC, the amount due for permanent total disability is US$60,000.00. The court also awarded attorney’s fees, citing Article 2208 of the New Civil Code, which allows for such fees in actions for indemnity under workmen’s compensation and employer’s liability laws. However, the court denied Deocariza’s claim for moral and exemplary damages, finding no evidence of ill-motive on the part of the respondents.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer was entitled to disability benefits under the POEA-SEC, considering his illness and the employer’s claim of concealment of a pre-existing condition.
Did the seafarer conceal a pre-existing condition?	The Supreme Court found insufficient evidence to prove that the seafarer concealed a pre-existing heart condition. The medical records and certifications did not support the employer’s claim of concealment.
Is aplastic anemia considered a work-related illness in this case?	Yes, the court determined that the seafarer’s aplastic anemia was work-related due to his exposure to benzene during his duties, which involved supervising the loading and unloading of vehicles.
What is the significance of the 240-day period?	Under the POEA-SEC, the company-designated physician has 120 days (extendable to 240 days) to provide a definitive assessment of the seafarer’s disability. Failure to do so results in a presumption of total and permanent disability.
What benefits is the seafarer entitled to?	The seafarer is entitled to US$60,000.00, representing total and permanent disability benefits under the 2010 POEA-SEC, and attorney’s fees.
Why were moral and exemplary damages denied?	The court denied the claim for moral and exemplary damages because there was no evidence of ill-motive on the part of the employer in denying the seafarer’s claim.
What does the POEA-SEC say about pre-existing conditions?	The POEA-SEC states that if a seafarer knowingly conceals a pre-existing illness, they may be disqualified from compensation and benefits, but the burden of proof is on the employer to demonstrate such concealment.
What are the conditions for an illness to be considered pre-existing?	An illness is considered pre-existing if the seafarer had received medical advice or had knowledge of the condition before the POEA contract processing, and it was undetectable during the pre-employment medical examination.

In conclusion, the Supreme Court’s decision underscores the importance of due diligence in assessing seafarers’ claims for disability benefits. It clarifies the burden of proof on employers to demonstrate concealment of pre-existing conditions and emphasizes the significance of timely and definitive medical assessments. This ruling serves as a reminder of the protections afforded to seafarers under the POEA-SEC and the need for fair and just application of its provisions.

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: Melchor Barcenas Deocariza v. Fleet Management Services Philippines, Inc., G.R. No. 229955, July 23, 2018