G.R. No. 84812 October 5, 1990
SEALANES MARINE SERVICES, INC. AND MARINE & TRANSPORTATION SERVICES (SAUDIA), LTD., petitioners, vs. THE HON. NATIONAL LABOR RELATIONS COMMISSION, PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION AND EVELYN F. ARANTE, respondents.

FACTS

Capt. Santiago Arante, Jr. was hired in May 1986 as master of M/V “Zuluf 8” for a one-year contract. While working on board in July 1986, he fell ill, was diagnosed with gastro-duodenitis in Saudi Arabia, and was repatriated. In the Philippines, subsequent medical examinations revealed he was suffering from a non-functioning gall bladder and, ultimately, cancer of the pancreas. He filed a complaint with the POEA for various benefits, including illness allowance, medical reimbursement, and death compensation. He passed away in June 1987, and his wife, Evelyn F. Arante, pursued the claim. The POEA awarded death compensation, burial allowance, medical reimbursement, airfare refund, sickness wages, and attorney’s fees. The NLRC affirmed the decision. Petitioners appealed, arguing the illness was pre-existing and not work-related, thus not compensable.

ISSUE

Whether the heirs of Capt. Arante are entitled to the benefits awarded under the standard employment contract for seafarers, notwithstanding that his illness (cancer of the pancreas) may not be work-connected.

RULING

The Supreme Court partially granted the petition. It set aside the award of death compensation (P250,000) because the evidence did not sufficiently establish that the cancer, which caused death, was contracted during the term of his employment. The Court noted the disease’s nature and the timeline of its discovery. However, the Court affirmed all other awards. The legal logic is grounded on the governing Standard Format Contract for seafarers, mandated by POEA Circular No. 2, Series of 1984. Under this contract, the compensability of illness or death is not contingent on a showing that it is work-related. The contract provides distinct benefits for incidents occurring during the term of employment. Since Capt. Arante manifested symptoms and became ill while under contract, he was entitled to the stipulated benefits for illness, which include: reimbursement of proven medical expenses (P67,045.73), a fixed burial allowance (P20,000), repatriation expense refund (US$344 for the deducted airfare), and sickness wages for 120 days (US$4,400). The Court held that the petitioners’ liability for these items arises from the contractual stipulations, not from the Labor Code provisions on occupational diseases, thus rendering their argument about the illness’s non-occupational nature irrelevant to these specific benefits. Petitioner Sealanes, having assumed the liabilities of the manning agent, was held solidarily liable.