We deny the seafarer’s claim for disability benefits due to fraudulent misrepresentation and medical abandonment, as provided under the 2000 Philippine Overseas Employment Administration Standard Terms and Conditions Governing the Employment of Filipino Seafarers on Board Ocean-Going Vessels (2000 POEA-SEC). This case emphasizes the importance of honesty during pre-employment medical examinations and adherence to prescribed medical treatments for seafarers seeking disability benefits.

The Case of the Hidden Hypertension: When a Seafarer’s Honesty Impacts His Benefits

This case revolves around Danilo A. Lerona, a seafarer employed by Sea Power Shipping Enterprises, Inc. He sought disability benefits after experiencing health issues during his employment. However, his claim was contested due to his failure to disclose a pre-existing condition and his premature termination of medical treatment. The Supreme Court ultimately sided with the shipping company, denying Lerona’s claim and highlighting the critical importance of transparency and adherence to medical protocols in maritime employment.

The central issue was whether Lerona was entitled to disability benefits, considering his concealment of hypertension during his pre-employment medical examination (PEME) and his subsequent abandonment of the medical treatment prescribed by the company-designated physician. The 2000 POEA-SEC governs the employment of Filipino seafarers and outlines the conditions under which disability benefits can be claimed. Section 20(E) of the POEA-SEC specifically addresses the issue of fraudulent misrepresentation, stating:

E. 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. This may also be a valid ground for termination of employment and imposition of the appropriate administrative and legal sanctions.

The Supreme Court emphasized that Lerona’s failure to disclose his hypertension, for which he had been taking medication for two years, constituted fraudulent misrepresentation. This act, according to the Court, was a direct violation of the POEA-SEC and a valid reason to deny his claim. The Court noted that Lerona had undergone multiple PEMEs prior to his deployments, providing him with ample opportunity to disclose his condition. His repeated concealment undermined his claim of good faith.

Even without the fraudulent misrepresentation, Lerona’s claim faced another significant hurdle: his failure to complete the prescribed medical treatment. The company-designated physician had scheduled a follow-up appointment for medical clearance, which Lerona failed to attend. The Supreme Court has consistently held that seafarers must comply with their duty to complete medical treatment until they are declared fit to work or assessed with a permanent disability rating. This principle is rooted in Section 20(D) of the 2000 POEA-SEC, which states:

[N]o compensation and benefits shall be payable in respect of any injury, incapacity, disability or death of the seafarer resulting from his willful or criminal act or intentional breach of his duties. x x x

By abandoning his treatment, Lerona prevented the company-designated physician from making a final assessment of his condition, effectively breaching his duties under the POEA-SEC. The Court cited the case of *C.F. Sharp Crew Management, Inc. v. Orbeta*, where it defined medical abandonment as “when he fails to complete his treatment before the lapse of the 240-day period, which prevents the company physician from declaring him fit to work or assessing his disability.”

The Court also addressed Lerona’s argument that he was entitled to benefits because he was unable to work for more than 120 days. The Court clarified that the 240-day rule applies in cases filed after October 6, 2008, allowing the company-designated physician a longer period to assess the seafarer’s condition. This extended period is crucial for proper diagnosis and treatment, ensuring a fair and accurate evaluation of the seafarer’s fitness for duty. In this instance, Lerona filed the case before the 240-day period had lapsed, and without a final assessment from the company doctor.

Furthermore, the court addressed the relevance of the PEME and its bearing on disability claims. While a “fit to work” declaration in a PEME suggests a seafarer’s suitability for duty at the time of the examination, it does not guarantee the absence of pre-existing conditions. The Supreme Court in *Status Maritime Corporation v. Spouses Delalamon*, clarified that “[t]he PEME is nothing more than a summary examination of the seafarer’s physiological condition; it merely determines whether one is ‘fit to work’ at sea or ‘fit for sea service’ and it does not state the real state of health of an applicant.”

In summary, the Supreme Court’s decision in this case serves as a reminder of the responsibilities of seafarers under the POEA-SEC. Honesty during the PEME and adherence to prescribed medical treatments are crucial for a successful disability claim. Failure to meet these obligations can result in the denial of benefits, regardless of the seafarer’s actual medical condition. This ruling underscores the importance of transparency and cooperation between seafarers and their employers in matters of health and disability.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer was entitled to disability benefits, considering his concealment of a pre-existing condition (hypertension) and his abandonment of medical treatment.
What is fraudulent misrepresentation in the context of seafarer employment?	Fraudulent misrepresentation occurs when a seafarer knowingly conceals a past medical condition during the pre-employment medical examination. This disqualifies them from receiving disability benefits under the 2000 POEA-SEC.
What is medical abandonment, and how does it affect a seafarer’s disability claim?	Medical abandonment happens when a seafarer fails to complete their medical treatment, preventing the company physician from making a final assessment. It is a breach of duty that can lead to the denial of disability benefits.
What is the significance of the pre-employment medical examination (PEME)?	The PEME is a summary examination to determine if a seafarer is fit to work at sea, but it is not a comprehensive assessment of their overall health. It does not excuse the seafarer’s responsibility to disclose pre-existing conditions.
What is the role of the company-designated physician in disability claims?	The company-designated physician is primarily responsible for assessing the seafarer’s fitness for work or determining their disability within a specified period. Their assessment is crucial in determining eligibility for disability benefits.
What is the 120/240-day rule in seafarer disability cases?	The company doctor has 120 days to assess the seafarer’s condition or 240 days if further treatment is required. The 240-day rule applies in cases filed after October 6, 2008, allowing the company-designated physician a longer period to assess the seafarer’s condition.
What happens if a seafarer disagrees with the company-designated physician’s assessment?	Under Section 20(B)(3) of the 2000 POEA-SEC, a seafarer has the right to seek a second opinion from another doctor if they disagree with the company-designated physician’s assessment.
What are the requirements for hypertension to be considered a compensable occupational disease under the 2000 POEA-SEC?	Under Section 32(A)(20) of the 2000 POEA-SEC, hypertension is compensable if it causes impairment of function of body organs like kidneys, heart, eyes, and brain, resulting in permanent disability and is substantiated by medical reports.

This case highlights the need for seafarers to be forthright about their medical history and to adhere to the prescribed treatment plans. Failing to do so can have significant consequences for their ability to claim disability benefits.

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: DANILO A. LERONA v. SEA POWER SHIPPING ENTERPRISES, INC., G.R. No. 210955, August 14, 2019