G.R. No. 206256 , February 24, 2016
ALBERT C. AUSTRIA, Petitioner, vs. CRYSTAL SHIPPING, INC., and/or LARVIK SHIPPING A/S, and EMILY MYLA A. CRISOSTOMO, Respondents.

FACTS

Petitioner Albert C. Austria was hired as Chief Cook by respondent Crystal Shipping, Inc. He underwent a Pre-Employment Medical Examination (PEME) and was declared “fit to work.” While on board the vessel, he began suffering from chronic cough, phlegm, and breathing difficulties. After initial treatment abroad, he was declared fit for duty. However, his symptoms recurred, leading to his repatriation and subsequent diagnosis in the Philippines of “Dilated Cardiomyopathy, Bicuspid Aortic Stenosis,” which rendered him unfit for sea duty. Petitioner claimed this illness was work-related, aggravated by his working conditions, and sought permanent disability benefits under the Norwegian International Ship Register Collective Bargaining Agreement (NIS-CBA).
Respondents disavowed liability, arguing the illness was congenital and not caused or aggravated by his work as a Chief Cook. The Labor Arbiter ruled in favor of Austria, awarding disability benefits. The National Labor Relations Commission (NLRC) affirmed but deleted moral and exemplary damages. The Court of Appeals reversed, giving credence to the company physician’s opinion that the illness was congenital and not work-related.

ISSUE

Whether petitioner’s illness is compensable, having been aggravated by his working conditions, thereby entitling him to permanent disability benefits under the NIS-CBA.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the NLRC decision. The Court held that for an illness to be compensable, it is not required that the seafarer’s work be the sole cause; it is sufficient that his work contributed, even in a small degree, to the development or aggravation of the disease. The petitioner was in good health when he passed the PEME and commenced work. His duties as Chief Cook exposed him to extreme heat, chemicals, and stressful conditions, which could reasonably aggravate a pre-existing condition like cardiomyopathy.
The Court emphasized that the degree of proof required in labor cases is substantial evidence, not proof beyond reasonable doubt. Petitioner established through substantial evidence the reasonable connection between his work conditions and the aggravation of his illness. The company physician’s opinion that the illness was purely congenital failed to consider the potential aggravating factors of the onboard environment. Consequently, the illness is compensable under the NIS-CBA, and the NLRC committed no grave abuse of discretion in awarding the benefits.