G.R. No. 217879 , February 01, 2021
GERARDO U. VILLE, PETITIONER, VS. MAERSK-FILIPINAS CREWING, INC. AND/OR A.P. MOLLER A/S, RESPONDENTS.

FACTS

Petitioner Gerardo U. Ville was hired by respondent manning agency Maersk-Filipinas Crewing, Inc. as Chief Cook on board the vessel “Adrian Maersk” for a six-month contract starting July 2011. He underwent a Pre-Employment Medical Examination (PEME) and was declared fit for work. He disembarked upon the expiration of his contract on March 1, 2012, without reporting any illness or injury during his employment. On March 7, 2012, Ville underwent another PEME for redeployment, where he first disclosed a history of hypertension and medication. This PEME revealed Coronary Artery Disease, and he was declared “Unfit for Sea Duty.” Subsequent tests, including a Myocardial Perfusion Scintigraphy and a Coronary Angiography, confirmed a diagnosis of “3 Vessel Coronary Artery Disease.” A physician later certified that Ville should not be employed as a seafarer. Ville filed a complaint for total and permanent disability benefits, arguing his duties caused stress and fatigue that aggravated a heart ailment existing before disembarkation but only detected post-repatriation. Respondents contended his illness was not work-related, was pre-existing, and that Ville failed to undergo a mandatory post-employment medical examination within three days of repatriation.

ISSUE

Whether or not petitioner Gerardo U. Ville is entitled to total and permanent disability benefits.

RULING

No. The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, holding that Ville is not entitled to disability benefits. The Court ruled that for an illness to be compensable under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC), it must be work-related and must have existed during the term of the seafarer’s contract. Ville’s coronary artery disease was diagnosed only in August 2012, five months after his contract ended on March 1, 2012. He completed his contract without any medical complaint or issue, and his repatriation was due to contract completion, not medical reasons. This weakened his claim that the illness existed during his employment. The Court also found that Ville failed to present substantial evidence proving his hypertension and heart disease were work-related or aggravated by his working conditions as Chief Cook. He did not describe his working conditions with particularity or provide expert medical opinion linking his illness to his work. Furthermore, the Court emphasized Ville’s failure to comply with the mandatory requirement under the POEA-SEC to report to the company-designated physician for a post-employment medical examination within three working days upon his repatriation. His PEME on March 7, 2012, was for redeployment, not the required post-employment examination, and thus did not constitute compliance. This failure barred his claim for disability benefits.