G.R. No. 234711 , March 2, 2020
DAISY REE CASTILLON, JUREEZE PHOEBE CASTILLON, AND DREW WYATT CASTILLON, PETITIONERS, VS. MAGSAYSAY MITSUI OSK MARINE, INC. AND/OR FRANCISCO D. MENOR AND/OR MOL SHIP MANAGEMENT CO., LTD., RESPONDENTS.

FACTS

Junlou H. Castillon was employed as an Able Seaman by respondent Magsaysay Mitsui Osk Marine, Inc. He was deployed on February 23, 2009. In June 2009, he complained of intermittent mild stomach pains. By August 2009, the pain became severe and he discovered blood in his stool. A doctor in Japan declared him unfit for duty and recommended repatriation, suggesting tests to rule out malignancy due to his symptoms and family history of intestinal malignancy. He was repatriated on September 3, 2009. The company-designated physician diagnosed him with an abdominal mass but determined his condition was not work-related. Castillon underwent further tests in Iloilo, which revealed Sigmoid Colon Carcinoma Stage III.B. He informed the respondent of the needed operation, and the company provided an estimated cost. The operation was conducted on November 3, 2009. On December 12, 2009, Castillon requested financial assistance for chemotherapy. On August 26, 2010, the respondent asked Castillon to appear before the NLRC in Quezon City, where he signed a pro-forma labor complaint and then a “Release of All Rights” quitclaim in exchange for US$20,000.00 (P888,340.00). The quitclaim was presented to and approved by Labor Arbiter Melquiades Sol Del Rosario, who issued an order of dismissal with prejudice. Subsequently, on October 1, 2010, Castillon filed a complaint for disability and other benefits. The Labor Arbiter dismissed the case, a decision affirmed by the NLRC and the Court of Appeals. The CA ruled the quitclaim was knowingly and voluntarily executed and barred his claim, and that his illness was not work-related. Castillon died during the pendency of his motion for reconsideration. His heirs (petitioners) filed a Petition for Review before the Supreme Court.

ISSUE

Whether the quitclaim signed by Junlou H. Castillon is valid and bars his heirs from claiming disability and death benefits.

RULING

The Supreme Court granted the petition. The quitclaim is void. The amount received (US$20,000.00) is unconscionably low compared to the benefits legally due. Castillon was entitled to total and permanent disability benefits of US$60,000.00, and upon his death, his beneficiaries are entitled to death benefits of US$50,000.00 plus US$7,000.00 for each of his three children (total US$71,000.00), and burial expenses of US$1,000.00. The Court found the illness, Sigmoid Colon Carcinoma, to be work-related. The element of work-relatedness only demands a reasonable link between the illness and the seafarer’s work, not direct causation or that the work was the sole factor. Castillon was declared fit upon hiring, and the illness manifested during his contract. The stressful nature of his work and diet on board (canned goods high in fat) provided a reasonable connection. The company-designated physician’s contrary opinion was not supported by substantial evidence. The proceedings before Labor Arbiter Del Rosario were a sham, as the complaint was pro-forma and immediately settled to facilitate the quitclaim, depriving Castillon of due process. The defense of res judicata fails because the first dismissal was based on a void agreement. The respondents are ordered to pay the petitioners the aforementioned benefits, plus attorney’s fees.