G.R. No. 208215. April 19, 2017.
C.F. SHARP CREW MANAGEMENT, INC., NORWEGIAN CRUISE LINE, LTD. AND/OR MR. JUAN JOSE ROCHA, PETITIONERS, VS. RHUDEL A. CASTILLO, RESPONDENT.

FACTS

Respondent Rhudel A. Castillo was hired as a Security Guard aboard the MV Norwegian Sun. While on board, he suffered a seizure, was diagnosed with a right parietal brain hemorrhage, and was repatriated for medical treatment. The company-designated physicians diagnosed him with a cavernoma, a congenital vascular malformation, and opined it was idiopathic and not work-related. Petitioners provided medical treatment and paid sickness wages for over seven months.
Castillo filed a complaint for permanent total disability benefits, claiming entitlement under the Norwegian Collective Bargaining Agreement. The Labor Arbiter and the National Labor Relations Commission dismissed the complaint, finding that the petitioners successfully rebutted the presumption of work-relatedness with the physicians’ certification that the illness was congenital. The CA reversed, holding that the presumption was not overcome due to alleged inconsistencies in the medical reports regarding the illness’s cause.

ISSUE

Whether the Court of Appeals erred in awarding permanent total disability benefits to respondent Castillo.

RULING

Yes, the Supreme Court reversed the CA and reinstated the NLRC decision dismissing the complaint. The legal logic centers on the application of the POEA-SEC and the burden of proof. Under Section 20(B), illnesses not listed are disputably presumed work-related. However, this presumption is not conclusive and can be rebutted by substantial evidence.
Here, the company-designated physicians consistently and unequivocally certified, after extensive evaluation and referral to a neurosurgeon, that Castillo’s cavernoma was a congenital disorder, not caused or aggravated by his work. The Court found no fatal inconsistency in the medical reports; the varying medical terminologies used (e.g., arterio-venous malformation, cavernoma) referred to the same congenital condition. Petitioners thus presented credible evidence to overthrow the legal presumption.
Conversely, Castillo failed to present any contrary medical opinion or evidence to establish work-connection or work-aggravation. His mere assertion of illness manifestation during the contract is insufficient. The entitlement to disability benefits requires proof of a work-related condition. Since petitioners successfully disproved work-relation, and Castillo did not prove otherwise, no disability compensation is due. The award of attorney’s fees was also deleted as his claim lacked legal basis.