In a significant ruling, the Supreme Court held that a seafarer is entitled to disability benefits when the employer fails to act on the company-designated physician’s recommendation for necessary medical treatment within the prescribed period. This decision underscores the employer’s responsibility to ensure timely medical assessment and treatment for seafarers, reinforcing the protection afforded to them under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC). This case highlights the importance of prompt action by employers in fulfilling their contractual obligations to seafarers in need of medical attention.

Open Heart, Closed Doors: When a Seafarer’s Health is Left Hanging

The case of Oscar M. Paringit v. Global Gateway Crewing Services, Inc. (G.R. No. 217123, February 06, 2019) revolves around a seafarer, Oscar M. Paringit, who sought disability benefits after developing severe heart conditions during his employment. Paringit’s employer, despite being informed by the company-designated physician about the need for open-heart surgery, failed to provide timely approval and support for the procedure. This inaction led Paringit to file a complaint, arguing that his condition rendered him permanently disabled and unfit for duty. The legal question before the Supreme Court was whether the employer’s failure to act on the physician’s recommendation entitled Paringit to disability benefits, especially when the company-designated physician did not issue a final disability assessment within the prescribed period.

Paringit entered into a six-month employment contract with Mid-South Ship and Crew Management, Inc., representing Seaworld Marine Services, S.A., as Chief Mate of the vessel Tsavliris Hellas. Prior to his deployment, he disclosed his high blood pressure during the pre-employment medical examination but was still declared fit for duty. During his employment, he experienced constant fatigue, stress, and blood in his feces. Upon docking in Las Palmas, Spain, he was rushed to the intensive care unit and diagnosed with decompensated cardiac insufficiency, severe anemia, and renal dysfunction. He was medically repatriated to Manila and admitted to YGEIA Medical Center, where he was diagnosed with congestive heart failure, hypertensive cardiovascular disease, valvular heart disease, and anemia secondary to upper GI bleeding.

Dr. Maria Lourdes A. Quetulio, the company-designated physician, prescribed medication and referred Paringit to a valvular heart specialist. The specialist recommended a repeat 2D echocardiogram and coronary angiography. The results indicated a severe valvular problem requiring open-heart surgery for valve replacement or repair, with possible coronary bypass graft. Despite the urgent need for surgery, Paringit’s employer did not approve the recommended procedure. Dr. Quetulio noted that Paringit hesitated to undergo the surgery and considered herbal treatment instead. Later, Dr. May S. Donato-Tan, a cardiologist at the Philippine Heart Center, declared Paringit permanently disabled and unfit for duty as a seaman, due to his heart condition. Paringit then filed a complaint for medical expenses and other money claims. It is important to note that he also executed a quitclaim, acknowledging receipt of US$6,636.70 as sickness allowance.

The Labor Arbiter ruled in favor of Paringit, finding that his illnesses were work-related or work-aggravated due to the type of food served and the stressful nature of his job. The National Labor Relations Commission (NLRC) affirmed this decision, upholding that Paringit was entitled to permanent total disability benefits. However, the Court of Appeals reversed the labor tribunals’ rulings, faulting Paringit for seeking alternative treatment and asserting that his complaint was premature since the 240-day medical treatment period had not yet lapsed. The Court of Appeals emphasized that it was his duty to consult a third doctor, as required by law. Paringit then filed a Petition for Review on Certiorari, assailing the Court of Appeals’ decision.

The Supreme Court focused on whether the Court of Appeals correctly determined if the NLRC committed grave abuse of discretion in granting Paringit’s disability claims. The Court emphasized that to grant a seafarer’s claim for disability benefits, the following requisites must be present: (1) he suffered an illness; (2) he suffered this illness during the term of his employment contract; (3) he complied with the procedures prescribed under Section 20-B; (4) his illness is one of the enumerated occupational diseases or is otherwise work-related; and (5) he complied with the conditions enumerated under Section 32-A for an occupational disease to be compensable. It was undisputed that Paringit was diagnosed with heart disease, anemia, and renal dysfunction while aboard the vessel, leading to his medical repatriation.

The Court noted that Paringit had complied with the post-employment medical examination and that the company-designated physician recommended open-heart surgery. However, the employer failed to act on this recommendation for several months. The Philippine Overseas Employment Administration Standard Employment Contract (POEA Standard Employment Contract) defines a work-related illness as any sickness resulting from an occupational disease listed under Section 32-A, with the conditions set therein satisfied. Paringit’s heart ailments were classified under cardiovascular events, as defined in Section 32-A(11) of the POEA Standard Employment Contract. The Court of Appeals had held that Paringit failed to prove the causal connection between his heart disease and work aboard the vessel, attributing it to poor lifestyle choices. The Supreme Court disagreed, noting that while Paringit took medication for his high blood pressure, the working conditions and mandatory diet aboard the vessel made it difficult to maintain a healthy lifestyle. He was served mostly high-fat, high-cholesterol, and low-fiber food, and his work as Chief Mate was stressful and required long hours.

Labor Arbiter Savari had noted that seafarers on ocean-going vessels are not free to choose their diet and must contend with preserved foods. She also found that Paringit, despite being hypertensive, was declared fit to work in his pre-employment medical examination, and the poor food choices in his workplace contributed to his heart disease. The NLRC upheld these findings. Magsaysay Maritime Services, et al. v. Laurel emphasized that for an illness to be compensable, it is sufficient that there is a reasonable linkage between the disease and the work undertaken. The Court also addressed the Court of Appeals’ assertion that Paringit’s complaint was premature. Vergara v. Hammonia Maritime Services, Inc., et al. clarified the rules for reckoning a seafarer’s permanent disability. The Court emphasized that a temporary total disability becomes permanent when declared by the company physician within the allowed periods or upon the expiration of the 240-day medical treatment period without a declaration of fitness to work or the existence of a permanent disability.

The Court pointed out that Dr. Quetulio recommended open-heart surgery, but the employer failed to act on it. With the employer’s silence, Dr. Quetulio could not issue the required disability assessment within the 120-day period, nor extend it to 240 days. The failure to issue a timely disability assessment was due to the employer’s inaction, not Paringit’s supposed inclination toward alternative treatment. Therefore, the labor tribunals did not err in giving credence to the private physician’s findings, who declared Paringit permanently disabled and unfit for duty as a seaman. The Court concluded that the compensability of Paringit’s condition was clear, but the employer delayed his treatment and raised unwarranted procedural barriers.

Shipowners have obligations to their crew members, who risk their lives for their businesses. The Court emphasized the importance of promptly attending to the health needs of those who make their businesses possible. The Supreme Court ultimately granted the Petition for Review on Certiorari, reversing the Court of Appeals’ decision and reinstating the rulings of the labor tribunals.

FAQs

What was the key issue in this case?	The key issue was whether the employer’s failure to act on the company-designated physician’s recommendation for open-heart surgery entitled the seafarer to disability benefits. This was particularly pertinent when the physician did not issue a final disability assessment within the prescribed period.
What did the company-designated physician recommend?	The company-designated physician, Dr. Quetulio, recommended that Paringit undergo open-heart surgery after diagnosing him with congestive heart failure, hypertensive cardiovascular disease, and valvular heart disease. This recommendation was based on the results of various laboratory tests and consultations with a cardiologist.
Why did the Court of Appeals reverse the NLRC decision?	The Court of Appeals reversed the NLRC decision because it believed Paringit prematurely filed his complaint before the 240-day medical treatment period lapsed. They also faulted him for considering alternative treatment and not consulting a third physician as required by law.
What was the Supreme Court’s ruling?	The Supreme Court reversed the Court of Appeals’ decision and reinstated the rulings of the labor tribunals, granting Paringit’s disability claim. The Court held that the employer’s inaction on the recommended surgery justified the award of disability benefits.
What is the significance of the POEA Standard Employment Contract?	The POEA Standard Employment Contract (POEA-SEC) sets the terms and conditions of employment for Filipino seafarers. It defines work-related illnesses and the procedures for claiming disability benefits, ensuring seafarers’ rights are protected.
What is the 120/240-day rule in disability claims?	The 120/240-day rule refers to the period within which the company-designated physician must assess the seafarer’s condition and issue a final disability assessment. The initial period is 120 days, which can be extended up to 240 days if further medical treatment is required.
What happens if the employer fails to act on the physician’s recommendation?	If the employer fails to act on the company-designated physician’s recommendation for treatment or assessment, the seafarer may be entitled to disability benefits. This is particularly true if the inaction prevents the physician from issuing a timely disability assessment.
What constitutes a work-related illness for seafarers?	A work-related illness for seafarers is defined as any sickness resulting from an occupational disease listed under Section 32-A of the POEA-SEC. The conditions under Section 32-A must be satisfied to establish compensability.

This case serves as a reminder of the obligations shipowners undertake when employing Filipino seafarers. Prompt attention to their health needs and adherence to contractual obligations are not only good business practices but also demonstrate a commitment to justice and the well-being of those who contribute to the success of the maritime industry.

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: OSCAR M. PARINGIT vs. GLOBAL GATEWAY CREWING SERVICES, INC., G.R. No. 217123, February 06, 2019