Bergesen D.Y. Philippines, Inc. v. Estenzo
REITERATIONFacts
1. The Antecedents: Respondent Rizalino M. Estenzo was employed by petitioner Bergesen D.Y. Philippines, Inc. as a deck fitter for a ten-month period. Approximately three months into his employment, the vessel on which he served was sold, leading to his repatriation. Subsequently, Estenzo applied for re-employment but was diagnosed with hypertensive cardiovascular disease with ischemia during a pre-employment medical examination. His condition was confirmed by another hospital, which declared him unfit for sea duty. Estenzo filed a claim for disability benefits with his employer, which was rejected, prompting him to file a complaint with the Labor Arbiter. 2. Procedural History: The Labor Arbiter ruled in favor of Estenzo, ordering the petitioners to pay disability compensation, damages, and attorney's fees. Upon appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, dismissing the complaint for lack of merit, finding that the employer-employee relationship had ceased and that Estenzo failed to prove his illness was work-connected. Estenzo's motion for reconsideration was denied. He then filed a petition for certiorari with the Court of Appeals, which reversed the NLRC's decision, reinstating the Labor Arbiter's ruling. The petitioners' motion for reconsideration was denied by the Court of Appeals. 3. The Petition: Petitioners Bergesen D.Y. Philippines, Inc. and Rolando C. Adorable seek review on certiorari under Rule 45 of the Rules of Civil Procedure. They contend that they are not liable for permanent disability benefits because Estenzo suffered his illness after his repatriation and the termination of their employer-employee relationship, citing Sections 18 and 23 of the POEA Standard Employment Contract. Conversely, Estenzo argues that his employment relationship was deemed uninterrupted under Section 3 of the TCC-CBA, as his repatriation was due to the vessel's sale and not his fault, thus maintaining the employer's liability for his disability benefits.
Issue(s)
Whether the termination of respondent's services precludes his entitlement to permanent disability benefits. Whether the Court of Appeals committed grave abuse of discretion in reversing the NLRC decision.
Ruling
The petition is denied. The challenged Decision and Resolution of the Court of Appeals are affirmed. Petitioners are liable to pay respondent his permanent disability benefits.
Ratio Decidendi
On the issue of whether the termination of respondent's services precludes his entitlement to permanent disability benefits: The Court held that the employer's responsibility for the seafarer's welfare subsisted even after repatriation due to the sale of the vessel, provided the pre-termination of employment was not attributable to the seafarer's fault. In this case, the respondent's employment was pre-terminated due to the sale of the vessel, an event not caused by his own making. Therefore, his services were deemed uninterrupted under Section 3 of the TCC-CBA. The POEA Standard Employment Contract, designed for the protection of Filipino seamen, must be construed liberally in their favor. Section 20 B of the contract mandates employer liability for injuries or illnesses during the term of employment, and even after repatriation if medical attention is still required until declared fit or the degree of permanent disability is assessed. The Court found that the respondent's illness, hypertensive cardiovascular disease with ischemia, was work-related, as evidenced by his pre-employment medical examination showing him fit for work and the nature of his strenuous duties in a hazardous environment. The Court of Appeals correctly found that the respondent's strenuous work as a deck fitter and the emergency overhauling job were the proximate cause of his illness. The Court reiterated that actual proof of causation is not necessary; probability and substantial proof are sufficient for compensability, consistent with the liberal interpretation of labor laws and the social justice policy of the State. Thus, the termination of employment due to the vessel's sale did not extinguish the employer's liability for permanent disability benefits. There was no discussion of the second issue in the provided text.
Main Doctrine
The employer's responsibility for a seafarer's welfare subsists even after repatriation due to vessel sale, if the pre-termination of employment is not attributable to the seafarer's fault, entitling the seafarer to permanent disability benefits under the POEA Standard Employment Contract.