G.R. No. 107131 March 13, 1997
NFD INTERNATIONAL MANNING AGENTS, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (SECOND DIVISION) and ROMEL BEARNEZA, respondents.

FACTS

Romel Bearneza was hired as a wiper by NFD International Manning Agents, Inc. for a ten-month contract commencing February 15, 1985. On November 8, 1985, while on board the vessel M/S Wilnina, he was mauled by four unidentified persons, suffering contusions and being diagnosed with epilepsy. He was declared unfit for work, repatriated, and subsequently examined at St. Luke’s Hospital, where he was declared fit to resume work on February 3, 1986. However, from September 25, 1986, to January 1, 1987, Bearneza was confined for 98 days at the Western Visayas Medical Center and diagnosed with “Schizophreniform Disorder,” which was assessed as a permanent total disability.
The POEA denied Bearneza’s claim for US$30,000 in permanent total disability benefits, reasoning that the Schizophreniform Disorder, diagnosed roughly seven months after he was declared fit to work, was entirely different and distinct from the earlier epilepsy. The NLRC reversed the POEA, granting the disability benefits. NFD International filed this petition for certiorari, arguing the ailment was acquired after the contract’s expiration.

ISSUE

Whether Romel Bearneza is entitled to permanent total disability benefits for his Schizophreniform Disorder.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC’s award of benefits. The legal logic centers on the established principle in compensation proceedings that probability, not the ultimate degree of certainty, is the test of proof, and strict rules of evidence do not apply. The Court found that Bearneza substantially established the causative link between his employment and his permanent disability. The mauling incident, which occurred during his employment, led to contusions and epilepsy. While he was declared physically fit in February 1986, no mental examination was conducted at that time to assess his psychiatric fitness. Critically, the petitioner failed to present sufficient medical evidence to definitively negate that the epilepsy caused by the work-related mauling could not have developed into the subsequent Schizophreniform Disorder. The temporal progression from the work-related injury to the permanent disability was deemed sufficient to establish compensability under the equitable and social justice principles governing labor cases. The NLRC, therefore, did not commit grave abuse of discretion in awarding the benefits.