Rillera v. United Philippine Lines, Inc.
REITERATIONFacts
The Antecedents: Petitioner Leonides P. Rillera was hired as 3rd Mate. Prior to deployment, he underwent a Pre-Employment Medical Examination (PEME) and answered negatively to questions about hypertension, heart disease, and diabetes, and was declared fit for sea duty. During his voyage, he complained of chest pain, shortness of breath, and difficulty breathing, leading to diagnoses of congestive heart failure, possible infectious endocarditis, and hypertension in Japan. He was medically repatriated. Upon repatriation, he was treated by company-designated doctors for various ailments, including pulmonary tuberculosis, left pleural effusion, diabetes mellitus, and later, knee pain and blurred vision. The company-designated doctors opined that his hypertension and diabetes were hereditary and not work-related, and eventually cleared him for work regarding his tuberculosis and diabetes. Petitioner consulted his own doctors who diagnosed him with hypertensive cardiovascular disease, pleural effusion, arthritis, and declared him permanently unfit for sea duties. Based on these findings, petitioner claimed total and permanent disability benefits, which respondents denied, citing his alleged fraudulent concealment of pre-existing conditions and failure to undergo the third doctor referral process. Procedural History: The National Conciliation and Mediation Board (NCMB) granted petitioner's claim for total and permanent disability benefits, finding that there was an existing CBA, petitioner was not guilty of material concealment, his failure to be referred to a third doctor should not work against him as the company-designated doctor did not make a categorical disability rating within 120 days, and his illnesses were presumed work-related or had a causative relation to his work. The Court of Appeals reversed the NCMB ruling, holding that petitioner was disqualified due to knowing concealment of his pre-existing hypertensive cardiovascular disease and diabetes, and that he failed to observe the proper procedure for contesting the company-designated doctor's findings by not initiating a referral to a third doctor. The CA also gave more weight to the company-designated doctor's findings over those of petitioner's chosen doctors and found no evidence that petitioner's osteoarthritis was work-related. The Petition: Petitioner seeks to reverse the Court of Appeals' decision, arguing that the failure to agree on a third doctor is not fatal to his claim, especially since the company-designated doctor failed to issue a definitive assessment within 240 days. He also contends that hypertensive cardiovascular disease is an occupational disease and diabetes is presumed work-related, and that his employment contributed to his illnesses. He further argues that the company-designated doctor lacked expertise in his case and that the Court of Appeals erred in giving more credence to the company-designated doctor's report.
Issue(s)
Whether petitioner was guilty of material concealment of a previous medical condition. Whether petitioner complied with the conditions prescribed under the 2010 POEA-SEC to entitle him to total and permanent disability benefits, assuming no material concealment.
Ruling
The petition is denied. The Court of Appeals' decision is affirmed, and petitioner's complaint for total and permanent disability benefits is dismissed.
Ratio Decidendi
On the issue of material concealment: The Court ruled that petitioner was guilty of material concealment. The records showed that petitioner had been diagnosed with hypertension in 2009 and diabetes in 2010, and was on maintenance medication for both. Despite this knowledge, he answered "no" to questions regarding these conditions in his January 2012 PEME. The Court emphasized that passing a PEME does not excuse willful concealment, as PEMEs are summary examinations and not exploratory. The Court cited the case of Lerona v. Sea Power Shipping Enterprises, Inc., et al., where a seafarer was denied disability benefits for concealing hypertension, noting that continued medication indicated the condition was not resolved. Petitioner's act of concealment was construed as an intention to deceive respondents regarding his true medical condition, which disqualifies him from receiving any disability compensation. On the issue of entitlement to disability benefits: Even assuming no concealment, the petition would still fail. The Court reiterated the conditions for compensability of occupational diseases under Section 32 of the POEA-SEC. For cardiovascular diseases, specific conditions must be met, including compliance with maintenance medications and doctor-recommended lifestyle changes if the seafarer is known to be hypertensive or diabetic. Petitioner, being a known hypertensive and diabetic, failed to show compliance with these requirements. The Court also noted that diabetes is generally considered an inherited, familial disease not work-related, citing GSIS v. Valenciano. Petitioner's osteoarthritis was also deemed not compensable due to lack of evidence of symptoms during employment and a causal connection to his work. Regarding the conflicting medical findings, the Court held that the company-designated doctors' assessments are given more weight because they had the complete medical records, conducted extensive examinations, and monitored the petitioner throughout his treatment. In contrast, petitioner's chosen doctors only saw him once. The Court cited Montierro v. Rickmers Marine Agency Phils., Inc. and Hernandez v. Magsaysay Maritime Corporation to support the principle that the company-designated physician's assessment, based on consistent treatment and monitoring, is more reliable.
Main Doctrine
A seafarer who knowingly conceals a pre-existing illness or condition in the Pre-Employment Medical Examination (PEME) is disqualified for any compensation and benefits. Passing a PEME does not excuse willful concealment, as it is not an exploratory examination and does not guarantee the discovery of all pre-existing conditions.