G.R. No. 209098, November 14, 2016
Juan B. Hernandez, Petitioner, vs. Crossworld Marine Services, Inc., Mykonos Shipping Co., Ltd., and Eleazar Diaz, Respondents.
FACTS
Petitioner Juan B. Hernandez was continuously employed by respondents under successive contracts from 2005. His last contract as Chief Cook aboard the M/V Nikomarin commenced on October 7, 2008, for nine months, later extended by five months, ending with his repatriation on December 19, 2009. His repatriation was due to contract completion, not medical reasons. In March 2010, for a prospective new contract, a pre-employment medical examination revealed he had hypertension and diabetes mellitus; he was declared fit for duty but required maintenance medication. Respondents, however, deferred his re-employment due to his health. In 2011, two independent physicians diagnosed him with hypertension stage 2 and type 2 diabetes mellitus, declaring him unfit for sea duty. Hernandez then claimed disability benefits, which respondents refused.
ISSUE
Whether petitioner is entitled to disability benefits and related claims under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).
RULING
Yes, the Supreme Court granted the petition, awarding disability benefits. The legal logic centers on the application of the disputable presumption of work-relatedness for illnesses not listed under the POEA-SEC and the compensability of an illness aggravated by work conditions. The Court found that while Hernandez’s hypertension and diabetes were pre-existing, as evidenced by his 2010 exam, they were aggravated by his duties as Chief Cook. His work involved provisioning, food preparation, cleaning, carrying heavy provisions, and constant exposure to varying climates and sea perils. Medical literature establishes that such physical and mental stress can exacerbate both hypertension and diabetes, making the illnesses compensable.
The Court rejected the respondents’ and the Court of Appeals’ strict reliance on the three-day post-employment medical examination rule. It ruled that the filing of the complaint itself constituted constructive compliance, as it served the purpose of contesting the company-designated physician’s assessment and seeking a determination of disability. Furthermore, the Court emphasized that technical rules of procedure should not frustrate the implementation of social legislation designed to protect labor. The conditions of Hernandez’s work contributed to the aggravation of his illnesses, entitling him to total and permanent disability benefits. The subsequent full settlement of his claims during the pendency of the case rendered the petition moot and academic, leading the Court to set aside the challenged CA decision.
