G.R. No. 206522 April 18, 2016
Doehle-Philman Manning Agency Inc., Dohle (IOM) Limited and Capt. Manolo T. Gacutan, Petitioners vs. Henry C. Haro, Respondent.

FACTS

Respondent Henry C. Haro was hired by petitioners as an oiler aboard MV CMA CGM Providencia for nine months. He underwent a pre-employment medical examination (PEME) and was declared fit for sea duty. In November 2008, while performing his duties, he experienced heartache and loss of energy after hammering and lifting a heavy machine. He was confined in a hospital in Rotterdam, informed of a hole in his heart, and repatriated on December 6, 2008. Upon repatriation, the company-designated physician, Dr. Leticia Abesamis, diagnosed him with “aortic regurgitation, moderate” and declared his condition not work-related. Despite this, petitioners continued his treatment, but respondent allegedly refused surgery and stopped reporting for follow-ups. On April 24, 2009, respondent’s personal doctor, Dr. Luminardo M. Ramos, declared him not fit to work. Respondent filed a complaint for disability benefits, claiming his illness was sustained during his employment and he was unable to work for more than 120 days. The Labor Arbiter and the NLRC dismissed the complaint, finding no evidence that his illness was work-related. The Court of Appeals reversed the NLRC, awarding respondent permanent total disability benefits and attorney’s fees, ruling that his inability to work for over 120 days entitled him to benefits.

ISSUE

Whether the Court of Appeals was correct in setting aside the NLRC Resolutions and awarding permanent total disability benefits to respondent.

RULING

No. The Supreme Court granted the Petition, reversing the Court of Appeals and reinstating the NLRC Resolutions dismissing the complaint. The Court held that for an illness not listed as an occupational disease, the seafarer must prove that the work conditions caused or at least increased the risk of contracting the illness. Respondent failed to provide substantial evidence of a causal connection between his work as an oiler and his aortic regurgitation. The company-designated physician’s declaration that the illness was not work-related, coupled with the lack of a contrary opinion from respondent’s personal doctor, remained unrebutted. Mere inability to work for more than 120 days is not the sole basis for awarding permanent total disability benefits; the illness must be shown to be work-related. The disputable presumption of work-relatedness was sufficiently overturned by the company physician’s assessment. Consequently, respondent was not entitled to disability benefits or attorney’s fees.