This case clarifies what constitutes a work-related injury for seafarers seeking disability benefits. The Supreme Court affirmed the denial of benefits to a casino dealer who claimed a back injury sustained on board was work-related but whose injury was traced to gym workout. The court emphasized that for an injury to be compensable, it must arise out of and in the course of employment, a link the seafarer failed to establish, and the court underscored the importance of proving a direct connection between the job duties and the injury sustained.

Beyond the Casino: When Does a Seafarer’s Injury Qualify for Disability Benefits?

Jose John C. Guerrero, a casino dealer, sought disability benefits from his employers, Philippine Transmarine Carriers, Inc. and Celebrity Cruises, alleging a back injury sustained while assisting an elderly passenger. He claimed that sometime in January 2012, he and other crew members were instructed to assist elderly guests out of the ship using wheelchairs during a gastro-intestinal outbreak, but a sudden motion caused him to lose balance leading to back pains, an injury documented to be lumbar spondylosis. The employers countered that Guerrero’s injury occurred during a workout at the crew gym, an activity unrelated to his job duties. The Labor Arbiter initially ruled in favor of Guerrero, but the National Labor Relations Commission (NLRC) reversed this decision, a reversal that was affirmed by the Court of Appeals (CA). Guerrero then elevated the case to the Supreme Court. The central legal question was whether Guerrero’s injury was work-related, thus entitling him to disability benefits under the POEA’s Amended Standard Terms and Conditions.

The Supreme Court denied Guerrero’s petition, finding no grave abuse of discretion on the part of the NLRC and CA. The Court reiterated the principle that it is not a trier of facts, and the factual findings of quasi-judicial bodies like the NLRC, when affirmed by the CA, are generally conclusive. Moreover, the Court emphasized that for disability to be compensable, two elements must concur: first, the injury or illness must be work-related; and second, the work-related injury or illness must have existed during the term of the seafarer’s employment contract.Work-related injury pertains to injury(ies) resulting in disability or death arising out of, and in the course of, employment, therefore, it becomes imperative to determine the origin or cause of the incident, as well as the time, place, and circumstances surrounding it.

“For disability to be compensable, two elements must concur: (1) the injury or illness must be work-related; and (2) the work-related injury or illness must have existed during the term of the seafarer’s employment contract.”

Building on this principle, the Court highlighted that the burden of proof rests on the claimant, in this case Guerrero, to establish a causal connection between the nature of his employment and his injury. Guerrero failed to provide substantial evidence linking his work as a casino dealer to his lumbar disc injury. His claim of injury while assisting an elderly passenger lacked corroboration. On the other hand, the respondents presented Guerrero’s Crew Injury Statement admitting that his injury resulted from a gym workout. The document also indicated that the injury occurred during his break time. The Supreme Court considered the statement as a substantial evidence against the claim.

“On JAN 22, I went to the gym to do my usual workout after that I felt pain on my lower back. I went to see a doctor on that day and gave me 24 hrs. to rest after that I go back to work, but everytime I bend, I felt something painful on my left buttock so I decided to see the doctor again on March 4 after that the pain keeps coming back ever since.”

The Court noted the inconsistencies in Guerrero’s account of how the injury occurred. Initially, he claimed it was due to assisting a passenger, then later suggested the gym incident was an aggravating factor, and finally alleged a fall during the wheelchair incident. These inconsistencies undermined his credibility and weakened his claim. The Court found that Guerrero’s strenuous physical activity at the gym caused the injury, which was unrelated to his duties as a casino dealer. The Court thus supported the conclusion that Guerrero failed to prove work-causation of the injury.

Moreover, the Supreme Court emphasized that Guerrero’s arguments regarding the failure of the company-designated physician to issue a timely medical certificate and the opinion of his chosen physician were raised for the first time on appeal. Matters not alleged in the pleadings or raised during the proceedings below cannot be ventilated for the first time on appeal. The Court found Dr. Garcia’s assessment, declaring Guerrero unfit for sea service, unsupported by sufficient diagnostic tests and procedures. This assessment, based on a single consultation and lacking adequate justification, could not be taken at face value.

Ultimately, the Supreme Court reiterated that the constitutional policy of protecting labor should not be used to oppress employers. While committed to the cause of labor, the Court must also ensure justice is dispensed fairly, based on established facts, applicable laws, and prevailing jurisprudence. In this case, Guerrero’s failure to prove a work-related injury, coupled with inconsistencies in his claims, led to the denial of his petition, highlighting the importance of providing concrete evidence to support claims for disability benefits.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer’s back injury was work-related, thus entitling him to disability benefits under his employment contract. The Supreme Court ruled that the injury was not work-related since it resulted from his gym workout.
What does “work-related injury” mean in this context?	A work-related injury is one that arises out of and in the course of employment. This means there must be a causal connection between the nature of the seafarer’s work and the injury sustained.
Who has the burden of proving that an injury is work-related?	The seafarer claiming disability benefits has the burden of proving that their injury is work-related. They must present substantial evidence to support their claim.
What kind of evidence is needed to prove a work-related injury?	Substantial evidence, which a reasonable mind might accept as adequate to justify a conclusion, is required. This may include medical records, incident reports, and witness testimonies.
What happens if a seafarer’s account of how the injury occurred is inconsistent?	Inconsistent statements can undermine the seafarer’s credibility and weaken their claim for disability benefits. The court may view such inconsistencies as a lack of veracity.
Can a seafarer raise new arguments on appeal that were not presented earlier?	No, matters that were not alleged in the pleadings or raised during the initial proceedings cannot be raised for the first time on appeal. This is barred by estoppel.
What role does the company-designated physician play in determining disability?	The company-designated physician is responsible for assessing the seafarer’s medical condition and providing a medical assessment. Failure to issue a timely assessment can have legal implications.
How does the court balance the protection of labor with the rights of employers?	The court is committed to protecting labor but must also ensure fairness and justice for employers. Decisions are based on established facts, applicable laws, and jurisprudence, ensuring that both sides are treated equitably.

In summary, this case highlights the importance of establishing a clear and direct link between a seafarer’s job duties and the injury sustained to qualify for disability benefits. Inconsistencies in the seafarer’s account and failure to provide substantial evidence can be detrimental to their claim.

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: JOSE JOHN C. GUERRERO, VS. PHILIPPINE TRANSMARINE CARRIERS, INC., G.R. No. 222523, October 03, 2018