G.R. No. 206600 . December 07, 2016.
ALMA COVITA, FOR HER BEHALF AND IN BEHALF OF HER TWO MINOR CHILDREN, JERRY AND RON, BOTH SURNAMED COVITA, PETITIONER, V. SSM MARITIME SERVICES, INC. AND/OR MARITIME FLEET SERVICES PTE. LTD. AND/OR GLADIOLA JALOTJOT, RESPONDENTS.

FACTS

Seafarer Rolando Covita was hired as a Bosun on April 29, 2009, and was declared fit for sea duty after a Pre-employment Medical Examination (PEME). He boarded the vessel M/T Salviceroy on May 7, 2009. On May 14, 2009, he fell ill and was subsequently diagnosed with end-stage renal failure. He was medically repatriated on May 23, 2009, and the company-designated physician later certified that his chronic renal failure was not work-related. Rolando died on September 20, 2009.
His surviving spouse, Alma Covita, filed a claim for death benefits, contending that the illness was work-connected, aggravated by the stressful shipboard conditions. The Labor Arbiter granted the claim, finding that the illness manifested during the contract and that the seafarer’s prior service with the same employer contributed to his condition. The NLRC reversed, ruling the illness was not work-related, a decision affirmed by the Court of Appeals.

ISSUE

Whether the seafarer’s death from chronic renal failure is compensable under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).

RULING

The Supreme Court denied the petition and affirmed the CA and NLRC decisions. The legal logic centers on the burden of proof and the application of the disputable presumption under Section 20(B)(4) of the POEA-SEC. While the said provision creates a presumption that an illness not listed as an occupational disease is work-related, this presumption is disputable. The claimant must still present substantial evidence to prove a reasonable connection between the work and the illness. The Court found that the petitioner failed to discharge this burden.
The seafarer’s illness, end-stage renal failure, is a condition that develops over a long period and could not have been caused by his brief one-week service on his last contract. The mere allegation that his work was stressful, without credible medical or factual evidence demonstrating how his specific duties caused or aggravated his renal disease, is insufficient. The certification of the company-designated physician that the illness was not work-related stands unrebutted by any contrary medical opinion. Consequently, the presumption was successfully overturned by the respondents. The claim for death benefits therefore fails for lack of substantial proof of work-relation.