In disability claims filed by seafarers, illnesses not explicitly listed as occupational diseases are presumed to be work-related. However, this presumption is disputable, meaning the seafarer must present substantial evidence linking their condition to the nature of their work to successfully claim disability benefits. This case clarifies that seafarers cannot solely rely on this presumption but must actively demonstrate a reasonable connection between their illness and their job duties.

When a Sebaceous Cyst Sails into a Seafarer’s Disability Claim

The case of Mario C. Madridejos v. NYK-Fil Ship Management, Inc. revolves around a seafarer’s claim for disability benefits due to a sebaceous cyst. Madridejos, a Demi Chef, argued that his cyst was either work-related or aggravated by his working conditions aboard the vessel. The central legal question is whether Madridejos provided sufficient evidence to prove that his illness was connected to his employment, thereby entitling him to compensation under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC).

Madridejos claimed that he suffered from a sebaceous cyst on his abdomen during his employment with NYK-Fil Ship Management, Inc. He asserted that it was either caused or aggravated by his work as a Demi Chef. The timeline of events included his medical treatment in England, where the cyst was excised, followed by his repatriation to the Philippines. Madridejos argued that he was not able to finish his contract because of his medical condition and should be compensated.

NYK-Fil countered that Madridejos’ repatriation was due to the termination of his probationary contract, not his medical condition. They further contended that the sebaceous cyst was not work-related and that Madridejos failed to provide sufficient evidence to support his claim. The company emphasized that the cyst was a common ailment and that Madridejos was able to continue working for two months after the excision without any reported complications.

The Labor Arbiter initially ruled in favor of Madridejos, awarding him a Disability Grade of 7. However, the National Labor Relations Commission (NLRC) reversed this decision, finding Madridejos’ claim to be an afterthought and that the cyst was not work-related. The Court of Appeals (CA) affirmed the NLRC’s decision, leading Madridejos to elevate the case to the Supreme Court (SC).

The Supreme Court, in its decision, emphasized the importance of substantial evidence in seafarer disability claims. While illnesses not listed in Section 32 of the POEA-SEC are disputably presumed to be work-related, this presumption is not absolute. The seafarer must still provide evidence to demonstrate a reasonable connection between their illness and their work. The court reiterated that “substantial evidence is more than a mere scintilla” and should be relevant evidence that a reasonable mind might accept as adequate to support a conclusion.

The Court examined the evidence presented by Madridejos and found it lacking. Madridejos argued that he was involved in an accident while working on board the vessel, which led to the development of his cyst. However, he failed to provide any corroborating evidence, such as ship records or witness testimonies, to support his claim. Additionally, his claim that he was advised to return to the Philippines for further treatment was not supported by the medical records, which indicated that the excision was a minor procedure.

The Supreme Court also addressed the issue of whether the sebaceous cyst was work-related. While Madridejos claimed that his working conditions contributed to the development of the cyst, he failed to provide specific details about his job duties and how they were connected to his illness. The Court noted that a sebaceous cyst is a common ailment that can develop due to various factors, such as infection or clogged sebaceous glands, and it is not necessarily caused by work-related activities.

The Court highlighted the importance of the pre-employment medical examination (PEME), but clarified its limitations. While Madridejos argued that his PEME indicated that he was “fit to work,” the Court stated that a PEME is not a comprehensive assessment of a seafarer’s health and may not detect all underlying conditions. The PEME primarily serves to determine whether a seafarer is fit for overseas employment at the time of the examination.

The Supreme Court upheld the CA’s decision, finding that Madridejos failed to provide sufficient evidence to prove that his sebaceous cyst was work-related or that his repatriation was due to medical reasons. The Court emphasized that the burden of proof lies with the seafarer to establish a reasonable connection between their illness and their work, and Madridejos failed to meet this burden. The Court stated:

The disputable presumption implies “that the non-inclusion in the list of compensable diseases/illnesses does not translate to an absolute exclusion from disability benefits.” Similarly, “the disputable presumption does not signify an automatic grant of compensation and/or benefits claim.” There is still a need for the claimant to establish, through substantial evidence, that his illness is work-related.

The ruling reinforces the principle that while seafarers are entitled to protection under the law, they must also substantiate their claims with credible evidence. The case serves as a reminder that the disputable presumption of work-relatedness is not a substitute for concrete proof. The court recognized the company fulfilled its duty to provide necessary medical assistance when he was diagnosed with his cyst and was immediately referred to a hospital where the company shouldered all the expenses.

The Court emphasized that the constitutional mandate to provide full protection to labor is not a tool to oppress employers. When evidence contradicts compensability, the claim cannot prosper; otherwise, it causes injustice to the employer. The Supreme Court, aligning itself with previous jurisprudence, reaffirmed that claims must be based on solid factual and legal grounds, not mere assumptions or unsubstantiated allegations. This principle ensures fairness and equity in the application of labor laws.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer, Madridejos, presented enough evidence to prove his sebaceous cyst was work-related, entitling him to disability benefits under his employment contract.
What does “disputable presumption” mean in this context?	A disputable presumption means that while an illness not explicitly listed as occupational is initially considered work-related, this can be challenged and disproven with sufficient counter-evidence. The seafarer must still substantiate their claim.
Why was Madridejos’ claim ultimately denied?	Madridejos’ claim was denied because he failed to provide substantial evidence linking his sebaceous cyst to his work environment or duties as a Demi Chef. The court found his assertions unsupported and inconsistent.
What kind of evidence could have strengthened Madridejos’ case?	Evidence such as ship records detailing an accident, witness testimonies corroborating his injury, or a medical expert’s opinion directly linking his cyst to his work conditions could have bolstered his claim.
What is the role of the Pre-Employment Medical Examination (PEME) in these cases?	The PEME establishes a baseline health condition but is not a comprehensive health assessment. It primarily determines fitness for overseas employment at the time of the exam, not a guarantee against future illnesses.
Was Madridejos’ repatriation due to his medical condition?	The court determined that Madridejos’ repatriation was due to the termination of his probationary contract, not his medical condition, based on the evidence presented.
What is the significance of Section 32 of the POEA-SEC?	Section 32 lists occupational diseases that are automatically considered work-related. Illnesses not on this list are subject to the disputable presumption and require additional evidence.
What is the standard of evidence required in seafarer disability claims?	The standard of evidence is “substantial evidence,” meaning relevant evidence that a reasonable mind might accept as sufficient to support a conclusion. It is more than a mere scintilla of evidence.

This case underscores the importance of meticulous record-keeping and the need for seafarers to gather comprehensive evidence to support their disability claims. While the law provides protection to seafarers, it also requires them to actively demonstrate the connection between their illness and their work to ensure fairness to both employees and employers.

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: MARIO C. MADRIDEJOS VS. NYK-FIL SHIP MANAGEMENT, INC., G.R. No. 204262, June 07, 2017