G.R. No. 193679 ; July 18, 2012
C.F. SHARP CREW MANAGEMENT, INC., NORWEGIAN CRUISE LINES and NORWEGIAN SUN, and/or ARTURO ROCHA, Petitioners, vs. JOEL D. TAOK, Respondent.

FACTS

Respondent Joel D. Taok was employed as a cook by petitioners under a POEA-approved contract. On July 25, 2006, while on board, he experienced chest pain and breathing difficulties. He was diagnosed with atrial fibrillation in Canada and repatriated on August 5, 2006. Upon arrival, he reported to the company-designated clinic for treatment. On September 18, 2006, he was diagnosed with cardiomyopathy and advised to return for re-evaluation on October 18, 2006.
Instead of continuing treatment, Taok filed a complaint for total and permanent disability benefits on September 19, 2006. The Labor Arbiter dismissed his claim, finding he had no cause of action as he filed while still under treatment and before any disability assessment. The NLRC affirmed but awarded sickness wages. The Court of Appeals modified the decision, granting Taok permanent total disability benefits, ruling that the company-designated physician failed to issue a final assessment within the 120-day period, thus entitling him to the claim.

ISSUE

Whether respondent Joel D. Taok is entitled to total and permanent disability benefits.

RULING

No. The Supreme Court reversed the Court of Appeals and reinstated the Labor Arbiter’s dismissal of the complaint. The legal logic centers on the premature filing of the claim and the failure to prove work-relatedness. Under the POEA-SEC and prevailing jurisprudence, a seafarer is entitled to disability benefits only upon a showing that the illness or injury is work-related and that a disability assessment has been made. Critically, Taok filed his complaint on September 19, 2006, while he was still within the 120-day temporary disability period and while he was still under treatment by the company-designated physician, with a follow-up scheduled for October 18, 2006. No final medical assessment of his disability had been issued at the time of filing. His act of filing the complaint constituted an abandonment of the treatment process, precluding a proper evaluation of his condition. Furthermore, the Court emphasized that atrial fibrillation and cardiomyopathy are not listed as occupational diseases. Taok failed to present substantial evidence to prove that his illness was work-related or that his working conditions caused or aggravated it. The burden of proof rests on the claimant, and his bare allegations were insufficient. Consequently, having filed prematurely and without establishing work-relatedness, he had no valid cause of action for disability benefits.