G.R. No. 230473 . April 23, 2018.
SEACREST MARITIME MANAGEMENT, INC. AND/OR HERNING SHIPPING ASIA PTE. LTD., PETITIONERS, VS. ALMA Q. RODEROS, AS WIDOW AND LEGAL HEIR OF FRANCISCO RODEROS, RESPONDENT.

FACTS

Seafarer Francisco Roderos was hired as Chief Cook aboard the vessel “MT ANNELISE THERESA.” During his contract in July 2011, he began experiencing constipation and abdominal pain. He was eventually repatriated and diagnosed in the Philippines with Stage 4 Colon Adenocarcinoma. The company-designated physician, Dr. Natalio Alegre, issued a report stating the illness was “deemed not work related,” citing genetic risk factors and noting colon cancer is not listed as an occupational disease in the POEA-SEC. Based on this, the petitioners discontinued medical support.
Roderos, and later his widow upon his death, filed a claim for disability benefits. The Labor Arbiter and the NLRC dismissed the complaint, upholding the physician’s assessment that the illness was not work-related. On appeal, the Court of Appeals reversed the NLRC, ruling the illness was compensable. The CA found that the nature of Roderos’s work as a cook, involving a diet of processed and low-fiber foods, constant stress, and exposure to kitchen heat and fumes, contributed to or aggravated his condition.

ISSUE

Whether the respondent established by substantial evidence that the seafarer’s work contributed to or aggravated his colon cancer, making it compensable.

RULING

Yes, the respondent established compensability. The Supreme Court affirmed the CA decision, awarding permanent total disability benefits. The legal logic proceeds from the principle that for an illness not listed as occupational under the POEA-SEC, the seafarer must prove, through substantial evidence, that the work conditions contributed to or aggravated the illness. The Court found this burden was met.
The Court rejected the petitioners’ sole reliance on the company doctor’s report, which focused on genetic factors. It emphasized that the report itself acknowledged dietary factors as a known risk for colon cancer. The Court held that the CA correctly considered the uncontroverted evidence regarding Roderos’s working conditions: his duties as Chief Cook necessitated a diet primarily of processed meats and canned goods, which are low in fiber and high in fat—a documented risk factor for colon cancer. Coupled with constant stress, physical strain, and exposure to extreme temperatures and fumes in the ship’s kitchen, these work-related exigencies were reasonably linked to the development or aggravation of his fatal illness. Therefore, the illness was compensable as work-related or work-aggravated under the governing contract and the principles of social justice and protection for overseas workers.