In Magsaysay Maritime Corporation v. Mazaredo, the Supreme Court affirmed the right of a seafarer to receive disability benefits for an illness deemed work-related, emphasizing the importance of the company-designated physician’s assessment within a specified timeframe. The Court found that if a company-designated physician fails to provide a conclusive assessment of a seafarer’s fitness to work within 120 or 240 days, and the seafarer remains unable to work, the seafarer is considered permanently and totally disabled, thus entitling them to corresponding benefits under the POEA SEC. This decision reinforces the protection afforded to seafarers under Philippine law, ensuring that their health and well-being are safeguarded throughout their employment.

Sailing Through Sickness: Can a Seafarer Claim Disability After Contract Expiration?

Virgilio L. Mazaredo, a long-time employee of Magsaysay Maritime Corporation, experienced back pain while working as an Upholsterer onboard the vessel MY “Tahitian Princess.” Upon medical repatriation and examination, he was diagnosed with coronary artery disease. Despite his condition, the company-designated physician did not provide a definitive assessment of his fitness to work within the mandated period. Mazaredo sought compensation for his disability, but the company denied his claim, arguing that his contract had expired and his illness was not work-related. The central legal question was whether Mazaredo was entitled to disability benefits, sickness allowance, and medical reimbursement, considering his illness and the circumstances surrounding his employment.

The Supreme Court addressed the issue of whether Mazaredo’s disability was compensable under the Philippine Overseas Employment Administration Standard Employment Contract (POEA SEC). The Court emphasized that cardiovascular diseases, including coronary artery disease, are compensable illnesses for seafarers. It noted that Mazaredo’s long-term employment with the company and the conditions he faced as a seafarer contributed to the development and exacerbation of his heart ailment. Factors such as exposure to varying temperatures, harsh weather conditions, and the emotional strain of being away from family were considered significant contributors.

The Court referenced Article 192 (c)(l) of the Labor Code and Rule X, Section 2 of the Amended Rules on Employees Compensation, highlighting the obligation of the company-designated physician to provide a definite assessment of the seafarer’s fitness to work or permanent disability within 120 or 240 days. Failure to do so results in the seafarer being deemed totally and permanently disabled. In this case, the company-designated physician recommended bypass surgery but did not issue a final assessment of Mazaredo’s fitness to work. The Supreme Court has consistently held that:

“Under Section 20.B of the POEA Standard Employment Contract, the employer is liable for payment of disability compensation arising from work-related illness/injury sustained or contracted during the period of the seafarer’s employment. Section 32-A of the same Contract enumerates what are deemed occupational illnesses, whereas Section 20.D specifically states that illnesses not listed are disputably presumed to be work-connected.”

Building on this principle, the Court referenced the cases of Magsaysay Mitsui OSK Marine, Inc. v. Bengson and Alpha Ship Management Corporation v. Cab, which established that a seafarer’s disability becomes permanent and total if no assessment is made within the statutory period and the seafarer remains unable to engage in gainful employment.

Additionally, the Court addressed the conduct of the petitioners’ counsels, Attorneys Herbert A. Tria and Jerome T. Pampolina, who repeatedly claimed the existence of a March 27, 2009 Medical Report favorable to their case, which was not found in the records. The Court sternly warned the counsels against such deceitful practices, reminding them of the ethical standards required of lawyers, as stated in the Code of Professional Responsibility:

“[a] lawyer shall not engage in unlawful, dishonest, immoral or deceitful conduct” (Rule 1.01); he “shall not, for any corrupt motive or interest, encourage any suit or proceeding or delay any man’s cause” (Rule 1.03); he “shall not do any falsehood, nor consent to the doing of any in Court, nor shall he mislead, or allow the Court to be misled by any artifice” (Rule 10.01); and he “shall not knowingly x x x assert as a fact that which has not been proved” (Rule 10.02).”

This approach contrasts with cases where the company-designated physician provides a timely and definitive assessment, which would typically carry more weight. However, the Court clarified that the absence of such an assessment, coupled with the seafarer’s inability to work, shifted the balance in favor of Mazaredo. Thus, the failure of the company-designated physician to issue a final assessment within the prescribed period, along with the established connection between Mazaredo’s work and his illness, entitled him to disability benefits, sickness allowance, and medical reimbursement.

The ruling underscores the importance of strict compliance with the POEA SEC and the Labor Code in ensuring the protection of seafarers’ rights. It serves as a reminder to employers to fulfill their obligations regarding medical assessments and compensation for work-related illnesses. Furthermore, it highlights the ethical responsibilities of lawyers to uphold honesty and integrity in their dealings with the courts.

FAQs

What was the key issue in this case?	The key issue was whether a seafarer was entitled to disability benefits when the company-designated physician failed to provide a definitive assessment of his fitness to work within the prescribed period.
What is the significance of the company-designated physician’s assessment?	The company-designated physician’s assessment is crucial for determining a seafarer’s fitness to work or the extent of their disability, which affects their entitlement to benefits.
What happens if the company-designated physician fails to provide a timely assessment?	If the physician fails to provide an assessment within 120 or 240 days, the seafarer may be deemed permanently and totally disabled, entitling them to disability benefits.
Is cardiovascular disease considered a compensable illness for seafarers?	Yes, the Supreme Court has consistently held that cardiovascular diseases, including coronary artery disease, are compensable illnesses for seafarers.
What factors contribute to a finding that an illness is work-related for seafarers?	Factors include the nature of their work, exposure to harsh conditions, long working hours, and the emotional stress of being away from family.
What is the POEA SEC, and why is it important?	The POEA SEC is the Philippine Overseas Employment Administration Standard Employment Contract, which sets the terms and conditions of employment for Filipino seafarers. It is essential for protecting their rights and ensuring fair treatment.
What ethical considerations were discussed in this case?	The Court addressed the unethical conduct of the petitioners’ counsels, who made false claims about the existence of a medical report, reminding them of their duty to be honest and truthful in their dealings with the court.
What is the effect of a seafarer’s employment contract expiring before a disability claim?	The expiration of the employment contract does not automatically negate a seafarer’s right to claim disability benefits, especially if the illness is work-related and manifested during the term of the contract.

This case reinforces the importance of protecting the rights and well-being of Filipino seafarers, who often face challenging working conditions and health risks. Employers must comply with their obligations to provide timely medical assessments and appropriate compensation for work-related illnesses.

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: Magsaysay Maritime Corporation, Princess Cruise Lines, Ltd. And/Or Mr. Eduardo U. Manese vs. Virgilio L. Mazaredo, G.R. No. 201359, September 23, 2015