G.R. No. 198097, July 30, 2014
STATUS MARITIME CORPORATION, MS. LOMA B. AGUIMAN, FAIRDEAL GROUP MANAGEMENT S.A., and MT FAIR JOLLY, Petitioners, vs. SPOUSES MARGARITO B. DELALAMON and PRISCILA A. DELALAMON, Respondents.

FACTS

Margarito Delalamon was hired as Chief Engineer by Status Maritime Corporation for its principal, Fairdeal Group Management S.A., to work on board M/T Fair Jolly. His contract was from July 26, 2005, to April 26, 2006, later extended to October 2006. In September 2006, while in the United Arab Emirates, he complained of loss of appetite and was diagnosed with “Renal Insufficiency: Diabetes Mellitus; IHD Blood+CBC+Anemia.” He was medically repatriated on September 6, 2006. Upon arrival, he was physically weak and did not report to the petitioners within three days as required by the POEA-SEC. His wife notified the petitioners through an intermediary. Margarito was hospitalized and diagnosed with “End Stage Renal Disease 2 Diabetic Nephropathy,” requiring regular dialysis. He died on September 11, 2007, from a Cardiovascular Accident. The respondents (spouses) filed a complaint for permanent disability benefits, sickness allowance, damages, and attorney’s fees. The Labor Arbiter and NLRC dismissed the complaint, finding the illness not work-related and noting the failure to report for post-employment medical examination. The Court of Appeals reversed, awarding sickness allowance and disability benefits, ruling the illness was work-related and the reporting requirement was excused due to his condition.

ISSUE

Whether Margarito Delalamon is entitled to permanent disability benefits and sickness allowance under the POEA-SEC.

RULING

No. The Supreme Court reversed the Court of Appeals and reinstated the dismissal of the complaint. The Court held that the respondents failed to substantiate the work-relatedness of Margarito’s illness. The medical report from the petitioners’ designated physician stated that “Chronic Kidney Disease secondary to Diabetic Nephropathy” is not work-related. In contrast, the respondents’ evidence, a medical evaluation from Dr. Efren Vicaldo stating the illness was “work aggravated/related,” was deemed insufficient as it lacked a detailed explanation of the causal connection between the illness and his work conditions. The Court emphasized that mere allegations of work-relation are inadequate; substantial evidence of a reasonable causal link is required. Furthermore, Margarito failed to comply with the mandatory three-day post-employment medical examination requirement under Section 20(B)(3) of the POEA-SEC without a valid excuse. His physical weakness upon arrival did not absolve him, as his wife’s notification to an intermediary did not constitute a formal report to the company-designated physician. The Court also noted that Margarito had a pre-existing condition of diabetes for six years, which he did not disclose during his pre-employment medical examination, potentially affecting the compensability of his claim. Therefore, the petitioners were not liable for the claimed benefits.