De Jesus v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Joel B. De Jesus applied for shipboard employment with respondent Pacific Ocean Manning, Inc. (POMI). During his pre-employment medical examination, he answered negatively to questions about prior ailments, including stomach pain or ulcer. He was subsequently hired as 4th Engineer. Early in his employment, De Jesus experienced severe stomach pains, diagnosed as a relapse of gastric ulcer, and was advised to sign off for treatment. He was repatriated to the Philippines. Upon his return, POMI refused to provide financial assistance and medical treatment, alleging De Jesus concealed his prior ulcer history and breached his contract by possessing ulcer medication without permission. De Jesus filed a complaint for unpaid wages, sickwage allowance, and medical expenses. Procedural History: The Labor Arbiter ruled in favor of De Jesus, finding that his misrepresentation could not be a basis for denying his claims, as he passed the medical examination and his illness was work-related or aggravated. The Labor Arbiter ordered POMI to pay unpaid salaries, medical allowance, and medical benefits. The National Labor Relations Commission (NLRC) reversed this decision, finding De Jesus guilty of unauthorized possession of medicines and intentional concealment of his ulcer history, thus disqualifying him from benefits. The Court of Appeals (CA) affirmed the NLRC's decision. The Petition: De Jesus appealed to the Supreme Court, questioning the denial of his claims for unpaid salaries, medical allowance, and reimbursement of medical expenses, and the imposition of repatriation costs on him.
Issue(s)
Whether petitioner shall be awarded his unpaid salaries, medical allowance and reimbursement of his medical expenses. Whether petitioner shall bear the cost of his repatriation.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals and its Resolution are REVERSED and SET ASIDE. The Decision dated August 28, 1998 of the Labor Arbiter is REINSTATED.
Ratio Decidendi
On the entitlement to unpaid salaries, medical allowance, and reimbursement of medical expenses: The Supreme Court held that an ailment contracted prior to employment does not preclude compensability if the employment contributed to its development or aggravation. De Jesus' claim that he was required to work during meal hours and that the food served was unsuitable contributed to the relapse of his ulcer. The Court reiterated that labor contracts are impressed with public interest and should be construed liberally in favor of seamen. Despite De Jesus' misrepresentation in his medical history, he passed the pre-employment medical examination and was declared fit to work, and was allowed to work for over two months. Therefore, his misrepresentation could not be a basis for denying his claims. Furthermore, the employer failed to prove that De Jesus breached his employment contract by possessing Cimetidine without permission. The Court emphasized that dismissal for such a violation requires strict adherence to the disciplinary procedures outlined in the POEA Standard Employment Contract, including written notice, investigation, and an opportunity for the seafarer to defend himself. Since there was no showing that these procedures were followed, the discharge was invalid. The burden of proof rests on the employer to establish just cause for dismissal, which POMI failed to do. Thus, De Jesus is entitled to his unpaid salaries, sickness allowance for 59 days, and reimbursement of medical expenses. On the cost of repatriation: The Court ruled that the cost of repatriation should be borne by the employer (Celtic and POMI) when a seafarer signs off for medical treatment and is declared fit for repatriation. This is consistent with Section 20(B)(4) of the Standard Employment Contract. The cost of repatriation should not have been deducted from De Jesus' unpaid salaries. Since De Jesus disembarked for medical reasons, the employer is responsible for the repatriation costs.
Main Doctrine
An employer cannot use an employee's misrepresentation in a pre-employment medical examination as a basis for denying claims if the employee was subsequently declared fit to work and the illness was work-aggravated. Furthermore, dismissal for possession of medicine without permission requires strict adherence to the prescribed disciplinary procedures, and the burden of proof rests on the employer to show just cause.