G.R. No. 208314 . August 23, 2017.
ANTONIO B. MANANSALA, PETITIONER, VS. MARLOW NAVIGATION PHILS., INC./MARLOW NAVIGATION CO. LTD./CYPRUS, AND/OR EILEEN MORALES, RESPONDENTS.

FACTS

Petitioner Antonio B. Manansala was hired as a fitter by respondents. During his Pre-Employment Medical Examination (PEME) on March 23, 2010, he specifically answered “NO” when asked if he had hypertension and diabetes mellitus. He was declared fit and deployed. On May 30, 2010, while on board, Manansala suffered a stroke, was hospitalized, and was subsequently repatriated. During his treatment by the company-designated physician, he again denied any history of diabetes and hypertension. The physician assessed him with a Grade 10 disability.
Manansala filed a complaint for total and permanent disability benefits. However, in a medical opinion dated December 20, 2010, his personal doctor, Dr. Amado San Luis, stated that Manansala had a long history of hypertension and diabetes and was taking maintenance medications (Enalapril and Metformin). This opinion declared him permanently disabled due to the high risk of another stroke. The Labor Arbiter and the National Labor Relations Commission dismissed his complaint, finding his ailments were pre-existing and not work-related. The Court of Appeals affirmed these rulings.

ISSUE

Whether or not petitioner Antonio B. Manansala is entitled to total and permanent disability benefits.

RULING

No, Manansala is not entitled to disability benefits. The Supreme Court denied the petition, affirming the lower courts’ decisions. The legal logic centers on the principle of compensability for work-related illnesses under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC). While seafarers, as laypersons, are not expected to make perfectly accurate medical disclosures and honest mistakes do not automatically negate compensability, the key distinction lies in the presence of fraudulent concealment.
In this case, the Court found that Manansala committed willful misrepresentation. He deliberately concealed his pre-existing conditions of hypertension and diabetes during his PEME and even during post-stroke treatment. This concealment was proven by the subsequent admission to his personal doctor of a long medical history and use of maintenance drugs—facts he actively withheld from the employer. His assertion that he properly disclosed his illnesses was contradicted by the PEME records and his consistent denials to the company physician. Since his stroke was a complication of these long-standing, concealed conditions and not shown to be aggravated by his work, it is not compensable as a work-related illness under the POEA-SEC. The employer’s right to select fit seafarers was vitiated by the fraudulent nondisclosure.