The Supreme Court has affirmed that a seafarer is entitled to total and permanent disability benefits if the company-designated physician fails to provide a final assessment within the extended 240-day period, regardless of any justification. This ruling clarifies the rights of seafarers to claim disability benefits when their medical conditions prevent them from returning to work, and it underscores the importance of timely and accurate medical assessments by company-designated physicians. It ensures that seafarers are not unduly delayed in receiving compensation for work-related illnesses.

Diabetes at Sea: Can Strenuous Work Lead to Disability Compensation?

Nelson M. Celestino, a third officer for Belchem Philippines, Inc., experienced severe health issues during his employment, leading to a diagnosis of diabetes mellitus and ureterolithiasis. Despite being initially declared fit to work, his condition worsened, resulting in his repatriation. The central legal question revolves around whether Celestino’s illnesses are work-related, entitling him to total and permanent disability benefits, and whether his claim was prematurely filed given the ongoing medical assessments by company-designated physicians.

The case hinges on the interpretation of the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) and the obligations of employers towards seafarers’ health. Central to the dispute is the timeline for medical assessments and the point at which a seafarer’s disability can be considered total and permanent. The Labor Arbiter initially ruled in favor of Celestino, but the National Labor Relations Commission (NLRC) reversed this decision, arguing that Celestino filed his complaint prematurely. This highlights the differing interpretations of the POEA-SEC and the evidence presented.

The Court of Appeals affirmed the NLRC’s decision, emphasizing that Celestino’s complaint was filed before the 240-day period for medical assessment had lapsed. However, the Supreme Court disagreed with the Court of Appeals, asserting that the complaint was not prematurely filed. The Supreme Court emphasized the guidelines set out in Orient Hope Agencies v. Jara, which provide a structured approach to determining a seafarer’s disability. According to these guidelines, the company-designated physician must issue a final medical assessment within 120 days, extendable to 240 days with sufficient justification. The critical point is that if no assessment is given within 240 days, the disability becomes permanent and total, irrespective of any justification.

In Celestino’s case, the Supreme Court noted that the 240-day period for assessing his disability ended on August 11, 2013. The advice from the company-designated physicians to undergo further treatment until August 31, 2013—twenty days beyond the 240-day limit—effectively indicated that his conditions were permanent, and his disability was total. The Court thus concluded that Celestino could not be faulted for filing his complaint on the 199th day of treatment. The Court’s reasoning underscores the importance of adhering to the stipulated timelines for medical assessments to protect the rights of seafarers.

Building on this, the Supreme Court addressed whether Celestino was entitled to total and permanent disability benefits. The POEA-SEC integrates into every seafarer’s contract, establishing the terms and conditions of their employment. Section 20(B)(4) of the POEA-SEC creates a disputable presumption that illnesses not listed as occupational diseases are work-related. This shifts the burden to the employer to prove that the illness is not work-related. Here, the Court examined Celestino’s working conditions, noting that he was exposed to various hazards and stresses. He performed physically strenuous tasks for long hours and was limited to the food available on the vessel.

The Court cited the case of Zonio v. 88 Aces Maritime Services, where it ruled in favor of the compensability of diabetes mellitus. The Court noted that the respondents failed to present evidence that Celestino’s illness was not caused or aggravated by his working conditions. This is crucial because in the absence of contrary medical findings or evidence that Celestino was predisposed to the illness, the stress and strains of his work were deemed to have contributed to his condition. It emphasized that compensability arises when a seafarer’s work conditions cause or increase the risk of contracting the disease. This ruling highlights the significance of demonstrating the causal link between work conditions and the onset of the illness.

Furthermore, the Supreme Court acknowledged that while diabetes mellitus is generally not compensable, it becomes compensable when complicated with other illnesses, citing Flores v. Workmen’s Compensation Commission. In Celestino’s case, his diabetes mellitus was complicated by ureterolithiasis, which has been previously deemed compensable. This point is significant because it broadens the scope of compensable illnesses for seafarers. It suggests that the presence of complicating factors can transform an otherwise non-compensable illness into a compensable one. This part of the ruling provides a more nuanced understanding of the types of illnesses that qualify for disability benefits.

The respondents argued that the pre-employment medical examination (PEME) presented by Celestino did not prove that his illnesses were acquired during his employment. However, the Court disagreed, citing Magat v. Interorient Maritime Enterprises, Inc., where it ruled that a PEME can indicate that a disability arose during employment. The fact that Celestino passed his PEME without any prior diagnosis of diabetes or ureterolithiasis strongly suggested that his illnesses developed while he was working as a third officer. Here the Court clarified that while a PEME is not conclusive proof, it carries significant weight in determining when the disability arose.

Finally, the Supreme Court addressed the issue of attorney’s fees. Article 2208 of the New Civil Code allows for the recovery of attorney’s fees in actions for the recovery of wages and indemnity under employer’s liability laws. Given that Celestino was compelled to litigate to protect his interests, the Court deemed the award of attorney’s fees appropriate. This part of the decision recognizes the financial burden faced by seafarers in pursuing their claims and ensures they are adequately compensated for their legal expenses. Ultimately, the Supreme Court reversed the Court of Appeals’ decision and reinstated the Labor Arbiter’s ruling, ordering Belchem Philippines, Inc., and Belchem Singapore Pte. Ltd., to pay Celestino his disability benefits and attorney’s fees. The Court also imposed a six percent legal interest per annum on the total monetary award from the finality of the decision until full payment.

FAQs

What was the key issue in this case?	The key issue was whether Nelson Celestino was entitled to total and permanent disability benefits for illnesses developed during his employment as a seafarer, and whether his claim was prematurely filed.
What is the significance of the 240-day period?	The 240-day period is the maximum time allowed for a company-designated physician to provide a final medical assessment of a seafarer’s disability. If no assessment is given within this time, the disability is considered permanent and total.
What is a PEME and why is it important?	A Pre-Employment Medical Examination (PEME) is a medical check-up a seafarer undergoes before deployment. It’s important because it establishes a baseline of the seafarer’s health and can indicate whether an illness developed during employment.
What does the POEA-SEC provide regarding work-related illnesses?	The POEA-SEC provides that illnesses listed as occupational are deemed work-related, and for those not listed, there is a disputable presumption that they are work-related. This places the burden on the employer to prove otherwise.
What was the Court’s basis for awarding attorney’s fees?	The Court awarded attorney’s fees because Celestino was compelled to litigate to protect his interests and recover his disability benefits, as allowed under Article 2208 of the New Civil Code.
How does this case affect future seafarer disability claims?	This case clarifies that seafarers are entitled to disability benefits if the company-designated physician fails to provide a timely assessment, reinforcing their rights under the POEA-SEC.
What illnesses did Celestino develop during his employment?	Celestino developed diabetes mellitus and ureterolithiasis, which are conditions that the Court considered in determining his eligibility for disability benefits.
What was the ruling of the Labor Arbiter versus the NLRC and Court of Appeals?	The Labor Arbiter initially ruled in favor of Celestino, while the NLRC and Court of Appeals reversed this decision, arguing his claim was premature. The Supreme Court ultimately sided with the Labor Arbiter.

In conclusion, the Supreme Court’s decision in the Celestino case reinforces the rights of seafarers to receive timely and fair compensation for work-related disabilities. The ruling underscores the importance of adherence to the medical assessment timelines set forth in the POEA-SEC, as well as the application of the disputable presumption that illnesses developed during employment are work-related. It serves as a reminder to employers of their obligations to ensure the health and well-being of their seafarers and to provide appropriate compensation when they suffer from 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: Nelson M. Celestino vs. Belchem Philippines, Inc., G.R. No. 246929, March 02, 2022