G.R. No. 155741 ; March 31, 2006
BARTOLOME C. PELAYO, Petitioner, vs. AAREMA SHIPPING AND TRADING CO., INC., MARITIMA FULLMAN, S.L., and PHILIPPINE TRANSMARINE CARRIERS, INC., Respondents.

FACTS

Petitioner Bartolome Pelayo was hired as a motorman for a ten-month contract. He was certified fit to work, with a normal electrocardiogram (ECG) result, prior to deployment in November 1994. His contract was extended, and he returned to the Philippines in December 1995. In January 1997, he filed a complaint for permanent disability benefits, alleging he developed a heart disease due to strenuous work on board the vessel. He claimed he experienced symptoms before his original contract expired in September 1995, was diagnosed with a heart ailment in Algeria, and was later discharged. Upon repatriation, he presented a Nigerian medical certificate diagnosing a heart condition, but respondents allegedly misplaced it. Petitioner subsequently obtained medical certifications in 1996 diagnosing “chronic stable angina” and “ischemic heart disease.”
Respondents denied petitioner complained of heart problems on board or upon arrival, asserting he only requested malaria examinations, for which he was cleared. They presented a “Deed of Receipts, Release and Quitclaim” executed by petitioner in April 1996. The Labor Arbiter and the National Labor Relations Commission (NLRC) dismissed the complaint, finding the alleged heart disease was not contracted during his employment. The Court of Appeals dismissed his petition for certiorari, ruling it raised factual issues improper under Rule 65.

ISSUE

Whether petitioner is entitled to disability benefits under the Philippine Overseas Employment Administration (POEA) Standard Employment Contract.

RULING

No. The Supreme Court denied the petition, affirming the Court of Appeals. The legal logic hinges on the requirement under the POEA Standard Employment Contract that for an illness to be compensable, it must be suffered during the term of the employment contract. The Court found petitioner failed to substantiate his claim that his heart disease was contracted or manifested during his employment. His pre-employment ECG was normal, and he did not present convincing medical evidence that he was diagnosed or treated for a heart condition while his contract was still in force. The medical certificates he later procured in 1996 were issued after his contract had already expired in December 1995. Consequently, they could not establish that his illness occurred during the term of his employment, a prerequisite for claiming disability benefits. The Court also accorded respect and finality to the consistent factual findings of the Labor Arbiter and the NLRC, which are deemed experts in labor matters, that the illness, if at all, arose after his contract expired.