G.R. No. 203161 ; February 26, 2014
MARTIN K. AYUNGO, Petitioner, vs. BEAMKO SHIPMANAGEMENT CORPORATION, EAGLE MARITIME RAK FZE, AND JUANITO G. SALVATIERRA, JR., Respondents.

FACTS

Petitioner Martin K. Ayungo was hired as Chief Engineer. During his pre-employment medical examination (PEME), he disclosed his Diabetes Mellitus but denied having Hypertension. He was declared “fit for sea duty.” While on board, Ayungo suffered hearing loss, vertigo, and lost consciousness. He was diagnosed in Japan with sudden dysacousis and later repatriated. In the Philippines, the company-designated physicians diagnosed him with Meniere’s Syndrome, Hypertension, Diabetes Mellitus, and later, Multiple Lacunar Infarcts and Coronary Artery Disease (CAD). They opined that his Hypertension and Diabetes were pre-existing, not work-related, and contributed to his condition.
Ayungo consulted an independent physician who declared him unfit for sea duty due to permanent total disability. He filed a claim for disability benefits. The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in his favor, awarding permanent total disability benefits. They held that the company assumed the risk by hiring him despite his disclosed Diabetes and that the company doctors’ findings were unsupported. The Court of Appeals reversed, dismissing Ayungo’s claim, finding his illnesses not work-related and pre-existing.

ISSUE

Whether Ayungo is entitled to permanent total disability benefits under the POEA-SEC.

RULING

Yes, the Supreme Court granted the petition and reinstated the NLRC decision. The legal logic proceeds from the disputable presumption of work-relatedness and compensability of an illness suffered during the term of employment under Section 20(B) of the POEA-SEC. The burden to rebut this presumption lies with the employer. Here, the respondents failed to discharge this burden. The Court found the company-designated physicians’ reports insufficient as they were conclusory, lacking in detailed justification explaining why the illnesses were not work-related or how the PEME could have missed the Hypertension. The mere fact that an illness is pre-existing does not automatically disqualify a claim; aggravation by work conditions remains compensable. The Court emphasized that the “fit to work” declaration in the PEME, despite the disclosed Diabetes, precludes the employer from later denying liability on the sole ground of a pre-existing condition. Since the employer failed to present substantial evidence to overcome the legal presumption, Ayungo’s claim for permanent total disability benefits is granted.