The Supreme Court has affirmed that a seafarer who suffers an illness during the term of their employment contract is entitled to disability benefits, even if the illness is not directly work-related. This ruling emphasizes the protection afforded to Filipino seafarers under the Philippine Overseas Employment Administration (POEA) Standard Employment Contract (SEC) and clarifies the scope of compensable disabilities. The Court prioritized the seafarer’s welfare, ensuring they receive just compensation for disabilities acquired while fulfilling their contractual obligations, promoting fair labor practices in the maritime industry. This decision underscores the importance of a liberal interpretation of seafarers’ contracts to uphold their rights and well-being.

When a Seafarer’s Heart Aches: Can Illness During Employment Guarantee Full Benefits?

In Micronesia Resources, Dynacom Shield Shipping Ltd. and Singa Ship Management, A. S. v. Fabiolo Cantomayor, the central legal issue revolved around determining the extent of disability benefits due to a seafarer, Fabiolo Cantomayor, who contracted coronary artery disease during his employment. Cantomayor sought permanent and total disability compensation, arguing that his condition rendered him unfit for continued work as a seafarer. The employers, Micronesia Resources, Dynacom Shield Shipping Ltd., and Singa Ship Management, contended that Cantomayor was only entitled to a Grade 7 partial disability compensation, based on the assessment of their company-designated physician, and further argued that his condition was pre-existing, thus not compensable. This case delves into the interpretation of the POEA Standard Employment Contract and the rights of seafarers to receive appropriate compensation for illnesses contracted during their employment, irrespective of direct work-relatedness.

The Court of Appeals (CA) reversed the decision of the National Labor Relations Commission (NLRC), which had sided with the employers. The CA ruled that Cantomayor was indeed suffering from a permanent and total disability, entitling him to full benefits under the law. Micronesia, et al., then elevated the case to the Supreme Court, questioning the CA’s decision on procedural and substantive grounds. They argued that Cantomayor’s petition for certiorari was filed late, making the NLRC decision final and executory. Furthermore, they asserted that the CA’s finding of total and permanent disability was baseless and that Cantomayor’s condition was pre-existing and not work-related. This case thus provides an opportunity to clarify the rights of Filipino seafarers under their employment contracts and the circumstances under which they are entitled to disability benefits.

The Supreme Court, in its decision, first addressed the procedural issue, dismissing the petitioners’ claim that Cantomayor’s petition was filed out of time. The Court emphasized that the CA has the discretion to grant motions for extension of time to file petitions, provided such motions are filed within the original filing period. Cantomayor had filed a motion for extension within the prescribed period, and his actual petition was filed within the extended deadline, thus rendering the petition timely filed. This procedural clarification reinforces the appellate court’s power to manage its proceedings and ensures that meritorious cases are not dismissed on mere technicalities.

On the substantive issue of Cantomayor’s disability benefits, the Supreme Court examined the applicability of the POEA Standard Employment Contract. The Court referenced Section 20-B(5) of the 1996 POEA-SEC, which stipulates the employer’s liabilities when a seafarer suffers injury or illness during the term of their contract. This provision states:

Section 20 Compensation and Benefits

x x x x

B. Compensation and Benefits for Injury or Illness

The liabilities of the employer when the seafarer suffers injury or illness during the term of his contract are as follows:

x x x x

5. In case of permanent total or partial disability of the seafarer during the term of his employment caused by either injury or illness, the seafarer shall be compensated in accordance with the schedule of benefits enumerated in Section 30 of his Contract. Computation of his benefits arising from an illness or disease shall be governed by the rates and the rules of compensation applicable at the time the illness or disease was contracted.

The Supreme Court affirmed that this provision serves as a legal basis for granting disability benefits to seafarers who suffer any injury or illness during their contract term. The Court emphasized that the phrase “during the term” covers all injuries or illnesses occurring within the contract’s duration, irrespective of whether they are directly work-related. This interpretation aligns with the principle of providing maximum aid and protection to labor, resolving any doubts in favor of the seafarer. The ruling reinforced that the contract’s stipulations, when not contrary to law, public policy, or morals, hold the force of law between the contracting parties.

In addressing the argument that Cantomayor’s illness was a pre-existing condition, the Supreme Court scrutinized the Pre-employment Medical Examination (PEME) results. While the PEME indicated a normal heart, it also noted “Poor R-waves progression NSSTTWC” in the ECG report. Despite this finding, the examining physician, designated by the employer, certified Cantomayor as fit to work. The Court held that the employers had the opportunity to screen and verify Cantomayor’s condition, as evidenced by the ECG findings. By hiring him despite these findings, the employers accepted liability for his subsequent illness during his employment. This determination underscores the importance of thorough pre-employment medical assessments and the employer’s responsibility to act on any disclosed health concerns.

The Court then addressed whether the amount awarded by the CA was proper, considering the company physician’s assessment limiting the disability to a Grade 7 impediment rate. The Supreme Court clarified that while the assessment of a company-designated physician is significant, it is not conclusive upon the seafarer or the court. The Court highlighted that Cantomayor was rendered unfit to discharge his duties as Third Officer for more than 120 days, a critical period in determining total and permanent disability. The medical records indicated ongoing chest pain and easy fatigability, inconsistent with the partial disability assessment. Consequently, the Court affirmed the CA’s decision to discard the Grade 7 disability assessment, declaring Cantomayor’s condition as a Grade 1 disability, thus entitling him to full compensation.

To further illustrate the concept of permanent total disability, the Court cited the case of Remigio v. National Labor Relations Commission, stating:

A total disability does not require that the employee be absolutely disabled, or totally paralyzed. What is necessary is that the injury must be such that the employee cannot pursue her usual work and earn therefrom. On the other hand, a total disability is considered permanent if it lasts continuously for more than 120 days.

The Court emphasized that permanent disability is defined as the inability of a worker to perform their job for more than 120 days, regardless of whether they lose the use of any part of their body. Total disability, on the other hand, means the disablement of an employee to earn wages in the same kind of work of similar nature that they were trained for or accustomed to perform. This principle underscores that the focus is on the employee’s inability to perform their usual work due to the illness or injury, rather than the absolute nature of the disability.

FAQs

What was the key issue in this case?	The key issue was whether a seafarer who suffered from coronary artery disease during his employment was entitled to permanent and total disability benefits under the POEA Standard Employment Contract.
What does the POEA Standard Employment Contract say about illnesses?	The 1996 POEA-SEC, specifically Section 20-B(5), stipulates that employers are liable when a seafarer suffers an injury or illness during the term of their contract, regardless of whether it is directly work-related.
What if the seafarer had a pre-existing condition?	Even if a seafarer had a pre-existing condition, if the employer hired them despite awareness or opportunity to know about it (such as through the PEME), they are liable for illnesses that manifest during employment.
What is considered a total and permanent disability?	A total disability is considered permanent if it lasts continuously for more than 120 days, rendering the employee unable to perform their usual work and earn wages in the same kind of work they were trained for.
Is the company doctor’s assessment final?	No, while the assessment of a company-designated physician is significant, it is not conclusive and can be challenged if inconsistent with the seafarer’s actual condition and inability to work.
How does the court interpret ambiguities in seafarer contracts?	The court interprets ambiguities in seafarer contracts in favor of the seafarer, aligning with the principle of providing maximum aid and protection to labor.
What was the outcome of the case?	The Supreme Court denied the petition, affirming the CA’s decision that Cantomayor was entitled to permanent and total disability benefits, as his condition rendered him unfit for continued work as a seafarer.
What is the relevance of the Pre-Employment Medical Examination (PEME)?	The PEME is crucial because it provides the employer with an opportunity to assess the seafarer’s health. Hiring a seafarer despite findings in the PEME may indicate acceptance of liability for subsequent related illnesses.

In conclusion, the Supreme Court’s decision in Micronesia Resources v. Cantomayor reinforces the rights of Filipino seafarers to receive just compensation for illnesses contracted during their employment. This ruling highlights the importance of adhering to the POEA Standard Employment Contract and ensuring that seafarers are adequately protected and compensated for disabilities suffered while fulfilling their contractual obligations. The case serves as a reminder to employers of their responsibilities to conduct thorough pre-employment medical examinations and to honor their contractual commitments to provide disability benefits.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MICRONESIA RESOURCES, DYNACOM SHIELD SHIPPING LTD. AND SINGA SHIP MANAGEMENT, A. S. VS. FABIOLO CANTOMAYOR, G.R. NO. 156573, June 19, 2007