G.R. No. 204076; December 4, 2013
JEBSENS MARITIME, INC., ESTANISLAO SANTIAGO, and/or HAPAG-LLOYD AKTIENGESELLSCHAFT, Petitioners, vs. ELENO A. BABOL, Respondent.

FACTS

Respondent Eleno A. Babol, a seafarer employed by petitioners, was diagnosed with Nasopharyngeal Carcinoma (NPC) during his employment. He underwent company-sponsored treatment but subsequently claimed permanent total disability benefits. Petitioners opposed the claim, arguing the company-designated physician found the illness was caused by genetic factors and not his work, and that they had provided full medical assistance.
The Labor Arbiter (LA) ruled in favor of Babol, awarding disability benefits. The LA found a causal relationship between the cancer and Babol’s diet on board the vessel, which included salt-cured foods, and held that petitioners failed to overcome the statutory presumption of work-relatedness. The National Labor Relations Commission (NLRC) affirmed the LA’s decision, noting the seafarer’s limited diet and exposure to toxic materials. The Court of Appeals (CA) subsequently dismissed the petitioners’ certiorari petition, upholding the findings of the labor tribunals.

ISSUE

Whether the Court of Appeals erred in affirming the award of permanent total disability benefits by ruling that respondent’s Nasopharyngeal Carcinoma is compensable as a work-related illness.

RULING

The Supreme Court DENIED the petition and AFFIRMED the CA decision. The Court upheld the award of permanent total disability benefits to respondent Babol.
The legal logic centers on the application of the disputable presumption of work-relatedness under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) and the principle of aggravation. The Court reiterated that for an illness to be compensable, it is sufficient that the work contributed to its development, even in a small degree. The labor tribunals and the CA correctly found that the risk factors for NPC, including a diet high in salt-cured foods and exposure to toxic fumes—conditions inherent in Babol’s work environment as a seafarer—were present. Petitioners’ evidence, including the physician’s opinion citing genetic causes, was deemed insufficient to substantially overthrow the legal presumption. The Court emphasized that the assessment of evidence by quasi-judicial agencies, when supported by substantial evidence, is accorded respect and finality. Furthermore, the Court clarified that the principle of aggravation is applicable, and prior employment with the same employer can be considered as it provides context to the seafarer’s prolonged exposure to alleged risk factors.