G.R. No. 217123 February 6, 2019
OSCAR M. PARINGIT, Petitioner vs. GLOBAL GATEWAY CREWING SERVICES, INC., MID-SOUTH SHIP AND CREW MANAGEMENT, INC., AND/OR CAPTAIN SIMEON FLORES, Respondents

FACTS

Petitioner Oscar M. Paringit was hired as Chief Mate. During his employment, he experienced constant fatigue and stress and noticed blood in his feces. He was eventually hospitalized in Spain and diagnosed with decompensated cardiac insufficiency, severe anemia, and renal dysfunction. He was medically repatriated. In the Philippines, the company-designated physician diagnosed him with Congestive Heart Failure, Hypertensive Cardiovascular Disease, Valvular Heart Disease, and Anemia secondary to a bleeding peptic ulcer. The physician recommended open heart surgery but noted Paringit’s hesitation towards the procedure. While awaiting his employer’s decision on the surgery, Paringit consulted an independent cardiologist, Dr. May Donato-Tan, who declared him permanently disabled and unfit for sea duty.
Paringit filed a complaint for permanent total disability benefits. The Labor Arbiter ruled in his favor, finding his illnesses work-related and awarding Grade 1 disability. The National Labor Relations Commission (NLRC) affirmed. However, the Court of Appeals reversed, giving more weight to the company physician’s assessment that the illness was pre-existing and not work-related, and that Paringit failed to complete the prescribed treatment.

ISSUE

Whether the Court of Appeals erred in reversing the NLRC and denying Paringit’s claim for permanent total disability benefits.

RULING

Yes. The Supreme Court reinstated the NLRC decision and granted Paringit permanent total disability benefits. The legal logic centers on the presumption of work-relatedness under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) and the failure of the company-designated physician to issue a timely and definitive assessment on Paringit’s disability.
An illness is presumed work-related if it occurred during the term of the contract. Paringit’s heart condition and related ailments manifested during his employment. The company physician’s belated claim of pre-existing condition, made only in a June 2012 letter after Paringit had filed his complaint, lacked credibility and did not overcome the legal presumption. Furthermore, the company physician failed to issue a final assessment within the 120/240-day period mandated by law. From Paringit’s repatriation in February 2012, the physician only gave interim recommendations for surgery without a definitive declaration of fitness or permanent disability. By June 2012, when Paringit consulted his own doctor, more than 120 days had lapsed without a final assessment from the company, resulting in a permanent and total disability by operation of law. The Court emphasized that seafarers are wards of the law, and doubts in the interpretation of labor contracts are resolved in their favor. The quitclaim he signed was invalid for being executed without the assistance of counsel and for waiving benefits far greater than the sickness allowance he received.