Philippine Transmarine Carriers v. Bernardo
REITERATIONFacts
The Antecedents: Respondent Raymond F. Bernardo, a 37-year-old messboy, was hired by petitioners Philippine Transmarine Carriers, Inc. and Furtrans Denizcilik Ticaret Ve Sanayi As for a nine-month contract. While onboard, he experienced ankle joint pain, diagnosed as "Artitis eotosa" in Morocco. He was medically repatriated and referred to a company-designated physician who initially diagnosed gouty arthritis, later clarifying it as a metabolic disorder not work-related, and subsequently as "Post Infectious Arthritis: Gouty Arthritis." Respondent underwent medical care and rehabilitation therapy from May 25, 2012, to December 17, 2012. He claimed treatment stopped despite his condition not being fully treated and consulted private physicians, including an orthopedic specialist who opined he was "permanently unfit to return to duty as a seafarer in whatever capacity with a permanent disability." Procedural History: Respondent filed a case for permanent total disability benefits under the POEA Standard Employment Contract (POEA-SEC). Petitioners argued gouty arthritis is not work-related, presenting certifications from company-designated physician Dr. Mylene Cruz-Balbon and medical specialist Dr. Vedasto Lim stating the condition is not work-related, citing diet, genetic predisposition, or under excretion of urate as causes. The Labor Arbiter (LA) ruled in favor of the respondent, finding the meals onboard contributed to the illness and awarding US$60,000.00 in disability benefits plus attorney's fees. The National Labor Relations Commission (NLRC) reversed the LA, holding that the presumption of compensability was overcome by Dr. Lim's certification and that the respondent's claim of dietary factors was belied by the ship's provisions list. The NLRC also noted the failure to follow the procedure for appointing a third doctor. The Court of Appeals (CA) reversed the NLRC, granting respondent's claim, finding it highly probable the infection was acquired onboard and that the high-purine diet onboard exacerbated his gouty arthritis. The Petition: Petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision and resolution granting respondent's claim.
Issue(s)
Whether gouty arthritis is a work-related condition and therefore compensable under the POEA-SEC.
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. The Court ruled that the respondent's illness is not compensable under the POEA-SEC.
Ratio Decidendi
On the issue of whether gouty arthritis is a work-related condition and therefore compensable: The Court reiterated that Section 20(A)(4) of the POEA-SEC provides a disputable presumption that illnesses not listed in Section 32 are work-related. Since post-infectious arthritis: gouty arthritis was not listed, it is presumed to be work-related. However, the Court emphasized that this presumption of work-relatedness does not automatically grant compensability. The seafarer bears the burden of presenting substantial evidence that their work conditions caused or at least increased the risk of contracting the disease, requiring only a reasonable proof of work connection, not a direct causal relation. In this case, the respondent relied on certifications from company-employed physicians, Dr. Lim and Dr. Cruz-Balbon, who opined that gouty arthritis is not work-related and can be caused by diet, genetic predisposition, or under excretion of urate. The Court noted that the findings of company-designated physicians are generally accorded great weight and credence. Furthermore, the Court considered several circumstances that collectively overcame the disputable presumption of work-relatedness. These included the respondent's relatively young age of 37 at the time of diagnosis, his second year as a seafarer, and his first employment contract with the petitioners. Statistics indicate gout is more prevalent in older men, making it less probable for a 37-year-old in his second year of seafaring to have a work-related condition. The list of food provisions for the vessel, consisting of a balance of fresh and frozen foods, also did not strongly support the claim that the onboard diet was the primary cause or aggravator of the illness. Therefore, the Court concluded that these circumstances sufficiently overcame the disputable presumption, rendering the respondent's illness not compensable under the POEA-SEC.
Main Doctrine
While Section 20(A)(4) of the POEA-SEC creates a disputable presumption that an illness not listed in Section 32 is work-related, compensability still requires the seafarer to present substantial evidence that their work conditions caused or at least increased the risk of contracting the disease. The findings of company-designated physicians are accorded great weight, and their certifications, along with other circumstances such as the seafarer's age and employment history, can overcome the disputable presumption.