Licayan v. Seacrest Maritime Management
REITERATIONFacts
The Antecedents: Petitioner Jay H. Licayan was hired as a Fitter for the vessel MT Clipper Ann by respondent Seacrest Maritime Management, Inc. He underwent a pre-employment medical examination and was declared fit for sea service. On September 7, 2011, Licayan experienced a severe headache and was diagnosed with vertigo and anxiety disorder, later definitively diagnosed as Trastorno or Panic Disorder in Cartagena, Colombia. He was repatriated to Manila and advised to report to the company-designated doctor, Dr. Natalio Alegre. Dr. Alegre certified that Licayan was suffering from Panic Disorder, Muscular Spasm-Cervical and Hypertension, and was "unfit to work" after more than 120 days from initial treatment. Licayan sought a second opinion from Dr. Elias Adamos, a clinical psychologist, who certified on July 2, 2012, that Licayan was permanently incapacitated to work as a seafarer due to Generalized Anxiety Disorder (Work-related) and Anxiety Disorder associated with or secondary to toxic chemical exposure, classifying it as Grade 1 under the POEA Standard Contract. Procedural History: Licayan filed a case for permanent total disability benefits, which was granted by the Labor Arbiter (LA) and affirmed by the National Labor Relations Commission (NLRC). The NLRC denied the motion for reconsideration filed by Seacrest. Aggrieved, Seacrest filed a petition for certiorari with the Court of Appeals (CA). The Petition: The CA reversed and set aside the NLRC decision, finding that Licayan failed to prove by substantial evidence that his illness was work-related. The CA ruled that the NLRC committed grave abuse of discretion. Licayan filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision.
Issue(s)
Whether or not the Court of Appeals erred and gravely abused its discretion in finding that Licayan has nothing to support his claim of work relatedness. Whether or not the Court of Appeals erred and gravely abused its discretion in ruling that there was no evidence that Licayan suffered an incident that contributed to his panic attack. Whether or not the Court of Appeals erred and gravely abused its discretion in denying to Licayan the permanent total disability compensation and attorney's fees.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Court of Appeals, and reinstated the decision of the National Labor Relations Commission. SO ORDERED.
Ratio Decidendi
On the issue of work-relatedness and substantial evidence: The Court found merit in the petition, holding that Licayan was able to prove by substantial evidence that his work conditions caused his panic disorder. The Court emphasized that under Section 20 (B) (4) of the POEA-SEC, illnesses not listed under Section 32-A are disputably presumed to be work-related, and it is incumbent upon the employer to overcome this presumption. Licayan's position paper detailed his exposure to harsh elements, perils at sea, severe stress, fatigue, irregular sleep patterns, and the extraordinary difficulty and pressure of installing water and oil separation fixtures and safety equipment while the vessel was on voyage, which unduly put him under pressure, resulting in loss of sleep, appetite, and emotional disorder. The Court found that the employer failed to overcome this presumption. On the issue of incidents contributing to panic attacks: The Court noted that Licayan's work as a Fitter involved not only his principal duties but also the installation of critical equipment like water and oil separation fixtures and safety equipment, especially while the vessel was on high seas. This extraordinary and difficult job, coupled with the general stresses of seafaring life, such as exposure to elements, perils at sea, and being away from family, created significant pressure. The Court found that the panic disorder was a manifestation of his emotional makeup being unable to endure the stresses entailed by these assignments, thus establishing a reasonable connection between his work and his condition. On the issue of permanent total disability compensation and attorney's fees: The Court found that Licayan suffered from a permanent total disability. This was supported by the fact that he was declared unfit to work by the company-designated physician, Dr. Alegre, and this finding was affirmed by Licayan's physician, Dr. Adamos, who declared him permanently incapacitated to work as a seafarer. The Court reiterated that permanent total disability means the inability to earn wages in the same kind of work, or work of similar nature, that he was trained for or accustomed to perform, or any kind of work which a person of his mentality and attainment could do.
Main Doctrine
For an illness not listed under Section 32-A of the POEA-SEC to be compensable, a disputable presumption of work-relatedness arises, and the employer must overcome this presumption by presenting substantial evidence that the claimant's work conditions caused or at least increased the risk of contracting the disease. A reasonable proof of work-connection, not direct causal relation, is required.