G.R. No. 195518 ; March 20, 2013
Magsaysay Maritime Services and Princess Cruise Lines, Ltd., Petitioners, vs. Earlwin Meinrad Antero F. Laurel, Respondent.

FACTS

Respondent Earlwin Laurel was employed as a second pastryman by petitioners. During his contract, he fell ill, complaining of fever and cough. He was eventually repatriated and diagnosed in the Philippines with hyperthyroidism. The company-designated physician issued a report stating the illness was not work-related. Laurel later consulted his own physician, Dr. Ramon Caceres, who diagnosed him with Graves’ Disease (hyperthyroidism) with periodic paralysis, advising against strenuous activity and assessing a Grade 1 impediment. Laurel filed a complaint for disability benefits.
The Labor Arbiter dismissed the complaint, ruling hyperthyroidism was not a listed occupational disease and Laurel failed to prove it was work-related. The NLRC reversed, awarding disability compensation. It held that the presumption of work-relatedness under the POEA-SEC applied, as the illness occurred during the term of employment, and the employer’s obligation to compensate arises from the seafarer’s incapacity to work. The Court of Appeals affirmed the NLRC’s decision.

ISSUE

Whether respondent Earlwin Laurel is entitled to permanent total disability benefits for his illness of hyperthyroidism.

RULING

Yes, the Supreme Court denied the petition and affirmed the award of disability benefits. The legal logic proceeds from the framework of the POEA-SEC and established jurisprudence. First, for an illness not listed as an occupational disease under Section 32 of the POEA-SEC, it is deemed work-related if the seafarer proves it was contracted during the term of his contract. The Court found Laurel’s illness manifested during his employment, satisfying this condition and triggering the presumption of work-relatedness.
Second, the petitioners failed to rebut this presumption convincingly. While their physician opined the illness was not work-related, the Court noted that medical literature indicates stress can be a significant aggravating factor for hyperthyroidism. The nature of Laurel’s work as a seafarer, involving prolonged periods at sea, could have contributed to such stress, thereby aggravating his condition. The employer’s defense was insufficient to overturn the legal presumption.
Finally, entitlement to disability benefits is based on the incapacity to labor and the impairment of earning capacity. Dr. Caceres’s assessment of a Grade 1 impediment and his advice against strenuous activity established that Laurel’s illness resulted in a permanent total disability, rendering him unfit for sea duty. The compensation is awarded for this loss of earning capacity, not merely for the illness itself. Therefore, the NLRC and CA correctly applied the law in granting the claim.