In a significant ruling for maritime employment, the Supreme Court held that while illnesses suffered by seafarers are presumed to be work-related, this presumption can be overturned by substantial evidence. This decision clarifies the burden of proof on seafarers claiming disability benefits and highlights the importance of medical evidence in establishing the link between a seafarer’s condition and their work environment. This means that seafarers need more than just a diagnosis to claim benefits; they need to demonstrate how their work specifically contributed to their illness, and employers can successfully challenge claims by presenting evidence to the contrary.

When Gout Strikes at Sea: Is it the Ship’s Diet or a Personal Predisposition?

This case revolves around Raymond F. Bernardo, a messboy who developed gouty arthritis while working on a vessel. The central legal question is whether his condition qualifies as a work-related illness, entitling him to disability benefits under the POEA Standard Employment Contract (POEA-SEC). Bernardo claimed that his diet aboard the ship contributed to his gout, while the petitioners, Philippine Transmarine Carriers, Inc., and Furtrans Denizcilik Ticaret Ve Sanayi As, argued that gouty arthritis is not work-related and pointed to Bernardo’s personal predisposition and general diet as potential causes.

The legal framework for seafarer disability claims is rooted in Section 20(A)(4) of the POEA-SEC, which states that illnesses not listed in Section 32 are disputably presumed to be work-related. This means that initially, Bernardo’s gouty arthritis was considered work-related unless proven otherwise. However, this presumption is not a guarantee of compensation. Section 32-A of the POEA-SEC outlines the conditions for an occupational disease to be compensable:

(1) the seafarer’s work must involve the risks described herein; (2) the disease was contracted as a result of the seafarer’s exposure to the described risks; (3) the disease was contracted within a period of exposure and under such other factors necessary to contract it; and (4) there was no notorious negligence on the part of the seafarer.

The Supreme Court emphasized that the disputable presumption of work-relatedness does not relieve the seafarer of the responsibility to present substantial evidence demonstrating that their work conditions caused or increased the risk of contracting the disease. This evidence does not need to establish a direct causal relationship but must provide reasonable proof of a work connection. In this case, Bernardo relied on certifications from medical professionals, including the company-designated physician, indicating that a high-purine diet could contribute to gouty arthritis. He argued that the meals provided on the ship aggravated his condition. However, the petitioners countered with evidence showing that the ship’s provisions included a balanced diet of fresh and frozen foods, including vegetables and fruits.

A critical factor in the Court’s decision was the opinion of the company-designated physician, who stated that Bernardo’s condition was not work-related. The Court gives significant weight to the findings of company-designated physicians, recognizing their expertise and role in assessing a seafarer’s medical condition. Additionally, the Court considered Bernardo’s age (37) and relatively short time as a seafarer (two years, with this being his first contract with the petitioners) at the time of diagnosis. Gout is statistically more prevalent in older men, making it less likely that his condition was solely attributable to his work environment. This statistical aspect further weakened the connection between his job and the illness.

The Supreme Court highlighted that while a legal presumption initially favors the seafarer, this presumption can be overcome by substantial evidence. The Court weighed the following factors against the presumption of work-relatedness: Bernardo’s relatively young age, his short tenure as a seafarer, the company-designated physician’s opinion, and the balanced nature of the ship’s food provisions. The interplay of these factors ultimately led the Court to conclude that the presumption of work-relatedness had been successfully rebutted.

The Court provided an outline of the burden of proof in cases involving the presumption of work-related illness:

Initial Presumption	Illness is presumed work-related under Section 20(A)(4) of the POEA-SEC.
Seafarer’s Responsibility	Must present substantial evidence linking work conditions to the illness. Reasonable proof of work connection is sufficient.
Employer’s Rebuttal	Employer must present substantial evidence to overcome the presumption.
Final Determination	The court weighs all evidence to determine if the presumption has been successfully rebutted.

This case underscores the need for seafarers to gather and present strong evidence demonstrating a clear link between their work environment and their medical condition. It also highlights the importance of medical assessments and the weight given to the opinions of company-designated physicians. Employers can successfully challenge claims by presenting evidence that contradicts the presumption of work-relatedness, particularly when factors such as pre-existing conditions, lifestyle choices, or statistical probabilities suggest alternative causes.

FAQs

What was the key issue in this case?	The central issue was whether the seafarer’s gouty arthritis was work-related and thus compensable under the POEA-SEC. The court had to determine if the presumption of work-relatedness was overcome by the evidence presented.
What is the POEA-SEC?	The POEA-SEC is the Philippine Overseas Employment Administration Standard Employment Contract, which governs the terms and conditions of employment for Filipino seafarers. It outlines the rights and responsibilities of both the seafarer and the employer.
What does “disputably presumed as work-related” mean?	It means that an illness is initially considered to be caused by the seafarer’s work, but this presumption can be challenged and overturned if the employer presents sufficient evidence to the contrary. The burden of proof shifts to the employer.
What kind of evidence did the seafarer present?	The seafarer presented medical certifications stating that a high-purine diet could cause or aggravate gouty arthritis and argued that the ship’s meals contributed to his condition. He sought to establish a connection between his diet on board and his illness.
What evidence did the employer present?	The employer presented an affidavit from a medical specialist stating that gouty arthritis is not related to seafaring duties. They also provided a list of food provisions showing a balanced diet on the ship and the opinion of the company-designated physician.
Why was the opinion of the company-designated physician important?	The court gives significant weight and credence to the findings of company-designated physicians due to their expertise in assessing seafarers’ medical conditions. Their assessment carries substantial authority in determining work-relatedness.
What factors did the court consider in overturning the presumption?	The court considered the seafarer’s age, short time as a seafarer, the opinion of the company-designated physician, and the balanced nature of the ship’s food provisions. These factors, taken together, overcame the presumption of work-relatedness.
What is the significance of this ruling for seafarers?	Seafarers must present strong evidence linking their work environment to their medical condition to support their claims for disability benefits. The presumption of work-relatedness is not automatic and can be challenged.
What is the significance of this ruling for employers?	Employers can successfully challenge claims by presenting evidence that contradicts the presumption of work-relatedness. Medical assessments and evidence related to working conditions are crucial.

This ruling serves as a reminder that while the law provides a degree of protection to seafarers through the presumption of work-relatedness, this protection is not absolute. Seafarers must be prepared to substantiate their claims with credible evidence, and employers have the right to challenge these claims with equally compelling evidence. The decision underscores the importance of a thorough assessment of the facts and circumstances of each case in determining entitlement to 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: Philippine Transmarine Carriers, Inc. vs. Raymond F. Bernardo, G.R. No. 220635, August 14, 2019