G.R. No. 219872 . September 09, 2020.
MAXIMINA T. MABUTE FOR AND IN BEHALF OF HER FOUR MINOR CHILDREN, PETITIONERS, VS. BRIGHT MARITIME CORPORATION AND/OR EVALEND SHIPPING CO., S.A. AND DESIREE P. SILLAR, RESPONDENTS.

FACTS

Jaime Mabute was deployed as Chief Engineer by respondent Bright Maritime Corporation. During his contract, he suffered from stomach pain, weakness, and significant weight loss. He was later hospitalized in China, diagnosed with conditions including a hepatic mass, and was medically repatriated. In the Philippines, the company-designated physician diagnosed him with Hepatocellular Carcinoma (liver cancer), stage 4, secondary to a long-standing, untreated Hepatitis B infection. The physician assessed the illness as non-work-related. Jaime passed away shortly after repatriation. Petitioner Maximina Mabute, Jaime’s wife, filed a claim for death benefits under the POEA-SEC.
The Labor Arbiter and the NLRC dismissed the claim, ruling the illness was not work-related and did not occur during the contract term, awarding only burial benefits. The Court of Appeals affirmed, holding that the petitioner failed to prove that the risk of contracting liver cancer was increased by Jaime’s working conditions and could not rely solely on the presumption of compensability.

ISSUE

Whether the heirs of the deceased seafarer are entitled to death benefits under Section 20(A) of the POEA-SEC.

RULING

Yes, the petitioners are entitled to death benefits. The Supreme Court reversed the lower tribunals. The legal logic centers on the application of the disputable presumption that an illness occurring during the term of the contract is work-related, as per the POEA-SEC. This presumption is bolstered by the fact that Jaime was declared fit to work in his pre-employment medical examination (PEME). While the company-designated physician opined the cancer was linked to a pre-existing Hepatitis B infection, the employer failed to substantiate its defense that the illness was pre-existing and that the PEME was fraudulent. The Court emphasized that the PEME is not exhaustive and cannot detect all latent conditions. Furthermore, the nature of Jaime’s work as Chief Engineer, involving exposure to chemicals, fumes, erratic schedules, and stressful conditions, could have aggravated his pre-existing condition. Since the employer did not successfully rebut the presumption of compensability and failed to prove the illness was exclusively due to a pre-existing condition unrelated to work, the claim is compensable. The death is deemed work-related, and the heirs are awarded the full death benefits.