G.R. No. 228296 , July 26, 2017
Grieg Philippines, Inc., Grieg Shipping Group AS, and/or Manuel F. Ortiz, Petitioners, vs. Michael John M. Gonzales, Respondent.

FACTS

Respondent Michael John M. Gonzales was hired by petitioner Grieg as an ordinary seaman. During his third nine-month contract aboard the vessel Star Florida in 2013, he experienced symptoms including shortness of breath, leg pain, fatigue, fever, and black tarry stools. After medical consultations in South Korea and Indonesia, he was diagnosed with pancytopenia, declared unfit for duty, and repatriated. In the Philippines, company physicians diagnosed him with acute promyelocytic leukemia but opined it was not work-related, though they continued treatment for humanitarian reasons. After a dispute regarding scheduled medical appointments, Gonzales consulted an independent physician who certified his illness as work-related. His claim for disability benefits was denied by Grieg, prompting him to file a complaint before the Labor Arbiter.
The Labor Arbiter ruled in favor of Gonzales, awarding permanent total disability compensation, sickness allowance, and attorney’s fees. The National Labor Relations Commission (NLRC) affirmed this decision. On appeal, the Court of Appeals (CA) also upheld the awards, applying the disputable presumption of work-relatedness for illnesses under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC). Grieg filed this Petition for Review, arguing Gonzales failed to prove the work-relation of his illness and that he was not entitled to attorney’s fees.

ISSUE

Whether the Court of Appeals erred in affirming the award of permanent total disability benefits and attorney’s fees to respondent Gonzales.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The legal logic centers on the application of the POEA-SEC provisions and the burden of proof in seafarer disability claims. The Court emphasized that for a disability claim to prosper, a seafarer need only show a reasonable linkage between his work and the illness, such that a rational mind could conclude the occupation may have contributed to or aggravated the disease. The Court noted that leukemia is listed as an occupational disease under Section 32-A of the POEA-SEC when specific conditions are met, shifting the burden to the employer to prove the illness is not work-related.
The Court found that Grieg failed to successfully rebut this presumption. The company physicians’ bare opinion that the leukemia was not work-related, without substantial evidence to disprove any reasonable connection to Gonzales’ shipboard duties, was insufficient. Furthermore, the Court upheld the finding that Gonzales did not abandon his medical treatment, as he communicated his difficulty in attending an appointment. Regarding attorney’s fees, the Court sustained the award, as Gonzales was compelled to litigate to obtain his rightful benefits. The factual findings of the Labor Arbiter, NLRC, and CA, being supported by evidence, are conclusive on the Supreme Court in a petition limited to questions of law.