GR 192754; (September, 2016) (Digest)
G.R. No. 192754. September 07, 2016.
LEONIS NAVIGATION CO., INC. AND WORLD MARINE PANAMA S.A., PETITIONERS, VS. EDUARDO C. OBRERO AND MERCEDITA P. OBRERO, RESPONDENTS.
FACTS
Petitioners Leonis Navigation Co., Inc. and World Marine Panama S.A. hired respondent Eduardo Obrero as a messman. During his contract onboard M/V Brilliant Arc in 2004, Obrero began exhibiting abnormal behavior, leading to his medical repatriation. He was diagnosed in Brazil with bipolar disturbance and later, in the Philippines by the company-designated physician, Dr. Nicomedes Cruz, with schizophreniform disorder. Dr. Cruz issued a certification stating the illness was not work-related but was linked to brain abnormalities and genetics, prompting petitioners to deny Obrero’s claim for total disability benefits.
Obrero filed a complaint before the NLRC. His personal physician, Dr. Pacita Ramos-Salceda, opined that his psychotic disorder was precipitated by continuous exposure to the stressful and adverse conditions at sea, including the stress of a demotion. The Labor Arbiter dismissed the complaint, but the NLRC reversed, finding the illness work-related. The Court of Appeals affirmed the NLRC, prompting petitioners to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether Eduardo Obrero’s schizophreniform disorder is compensable as a work-related illness under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).
RULING
Yes, Obrero’s illness is compensable. For an illness to be compensable under Section 20(B)(4) of the POEA-SEC, it must be work-related and must have arisen during the employment term. The second element is undisputed as the illness manifested during Obrero’s contract. On the first element, the POEA-SEC creates a disputable presumption that an illness not listed under Section 32 is work-related. While the seafarer must substantiate this presumption with substantial evidence, only reasonable proof of work-connection—not direct causal relation—is required.
The Court found such reasonable proof present. It rejected the company doctor’s bare assertion that the illness was “categorically not work-related,” noting it was an unexplained, cryptic comment. In contrast, Obrero’s evidence established that the inherent stress of seafaring—a rigorous, isolated, and confining occupation—acted as a trigger or aggravating factor for his psychological disorder. The Court emphasized that where an illness is precipitated or aggravated by the stressful working conditions peculiar to a seafarer’s job, it is compensable. The findings of the NLRC and the CA, which gave credence to this work-connection, were upheld as supported by substantial evidence. Thus, Obrero was entitled to total disability benefits.