G.R. No. 217135 . January 31, 2018.
MANILA SHIPMANAGEMENT & MANNING, INC., and/or HELLESPONT HAMMONIA GMBH & CO. KG and/or AZUCENA C. DETERA, Petitioners vs. RAMON T. ANINANG, Respondent.

FACTS

Respondent Ramon T. Aninang was employed as Chief Engineer by petitioners. During his contract, he experienced chest pain and shortness of breath. He requested early repatriation but his contract was instead extended. He was finally repatriated on February 2, 2011. Petitioners alleged that after repatriation, Aninang never reported for a mandatory post-employment medical examination with the company-designated physician. They claimed to have had no contact with him until receiving his complaint for disability benefits over a year later.
Aninang countered that upon arrival, he immediately reported to petitioner manning agency but was not referred to a company doctor. He thus consulted his personal physician, who later diagnosed him with congestive heart failure and declared him unfit for duty. He sought payment of disability benefits, which petitioners denied. The Labor Arbiter ruled in his favor, but the NLRC reversed, dismissing the complaint. The Court of Appeals then reinstated the Labor Arbiter’s decision, prompting this petition.

ISSUE

Whether the seafarer’s failure to submit to a post-employment medical examination by a company-designated physician within three working days from repatriation forfeits his right to claim disability benefits.

RULING

Yes. The Supreme Court reversed the Court of Appeals and reinstated the NLRC decision dismissing the complaint. The legal logic is anchored on the mandatory procedure under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC). Section 20(A)(3) requires a seafarer to submit to a post-employment medical examination by a company-designated physician within three working days upon arrival. This procedure is crucial as it affords the employer the opportunity to assess the seafarer’s condition and determine work-relatedness.
The Court emphasized that this requirement is a condition precedent to claiming disability benefits. Aninang’s failure to comply was fatal to his claim. His assertion that he reported to the manning agency but was not referred was deemed a self-serving allegation unsupported by evidence. The duty to report is personal to the seafarer; the employer’s alleged refusal does not excuse non-compliance. By consulting his own doctor without first undergoing the company-mandated examination, Aninang violated the POEA-SEC procedure. Consequently, he forfeited his right to disability benefits, as the law cannot be used to the detriment of an employer when the seafarer fails to observe the most basic contractual rules.