In a ruling concerning seafarer disability benefits, the Supreme Court emphasized that merely listing an illness under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) is insufficient for compensation. Seafarers must provide substantial evidence demonstrating a direct link between their illness and their work conditions. Furthermore, the Court outlined the responsibilities of voluntary arbitrators in resolving medical disputes, particularly concerning conflicting medical opinions, highlighting the importance of an expeditious resolution. This decision clarifies the evidentiary requirements for seafarers seeking disability benefits and the procedural steps for arbitrators in addressing medical disagreements.

When a Seafarer’s Health Falters: Is the Job to Blame?

The case of Raegar B. Ledesma v. C.F. Sharp Crew Management, Inc. arose from a claim for total and permanent disability benefits. Ledesma, employed as a Chief Fireman, experienced various health issues during his tenure, including hypertension, diabetes mellitus, chronic tonsillitis, and obstructive sleep apnea. Upon repatriation, conflicting medical opinions emerged between the company-designated physician and Ledesma’s chosen doctor, leading to a dispute regarding the work-relatedness of his conditions. The central legal question revolved around whether Ledesma presented sufficient evidence to establish that his illnesses were either caused or aggravated by his work environment aboard the vessel.

The Supreme Court scrutinized the evidence presented by Ledesma, focusing on whether he adequately demonstrated the connection between his medical conditions and his employment as a seafarer. The Court underscored that entitlement to disability benefits hinges not only on medical findings but also on legal and contractual provisions. The POEA-SEC defines a “work-related illness” as any sickness resulting from an occupational disease listed under Section 32-A of the contract, with the specified conditions satisfied. While illnesses not explicitly listed are disputably presumed as work-related, this presumption doesn’t automatically guarantee compensation. The seafarer must still provide substantial evidence linking the illness to their work.

In Ledesma’s case, the Court found that he failed to meet this evidentiary burden. Although he suffered from conditions such as hypertension and diabetes, which are sometimes listed as occupational diseases, he didn’t prove they were caused or exacerbated by his work. The Court referenced C.F. Sharp Crew Management, Inc. v. Santos, emphasizing that hypertension and diabetes do not automatically warrant disability benefits. Hypertension requires a showing of severity or gravity leading to permanent and total disability. Moreover, the POEA-SEC acknowledges that seafarers with hypertension or diabetes can still be employed if they adhere to prescribed medications and lifestyle changes.

Ledesma argued that his unhealthy diet aboard the vessel contributed to his hypertension, citing the unlimited food servings and lack of control over food choices. However, the Court deemed this insufficient evidence. Referencing Jebsens Maritime, Inc. v. Babol, the Court highlighted that assertions about high-risk dietary factors must be supported by credible information, demonstrating a causal relationship between the illness and working conditions. Mere allegations are inadequate. The Court noted the evolving standards governing food and catering on ocean-going vessels, as outlined in the 2006 Maritime Labor Convention, which emphasizes the suitability, nutritional value, quality, and variety of food supplies.

Regarding Ledesma’s chronic tonsillitis, the Court clarified that it doesn’t qualify as a compensable “infection resulting in complications necessitating repatriation” under the POEA-SEC. To be compensable, such infections must arise from specific conditions, such as working with animals infected with anthrax or handling animal carcasses. Ledesma failed to prove that his tonsillitis originated from these types of work conditions aboard the passenger vessel. Furthermore, the Court addressed Ledesma’s claim that his probable congestive heart failure wasn’t adequately treated or assessed.

The company-designated physician provided medical certificates detailing the cardiac diagnostic tests and treatments Ledesma received. The Court found that the company physician’s findings were based on extensive medical assessments, contrasting with the single medical certificate from Ledesma’s chosen physician, which lacked comprehensive medical history and failed to validate its findings with concrete medical and factual proofs. The court emphasized the importance of the medical assessment of the company doctor because that physician had evaluated the seafarer since the repatriation.

Addressing the issue of conflicting medical opinions, the Court affirmed the process for resolving such disputes. Section 20(A)(3) of the POEA-SEC outlines a mechanism involving a third doctor jointly agreed upon by the employer and seafarer, whose decision is final and binding. The Court cited Benhur Shipping Corporation v. Riego, clarifying that seafarers aren’t required to attach their doctor’s medical report when requesting referral to a third doctor. It is sufficient for the seafarer’s letter to indicate their doctor’s assessment of their fitness to work or disability rating, which contradicts the company-designated physician’s assessment.

While the Court acknowledged that Ledesma’s demand letter sufficiently disclosed his doctor’s assessment of unfitness, it emphasized that the respondents’ failure to act on this request empowered the labor tribunals and courts to conduct their own assessment based on the totality of evidence. The court emphasized that the chosen doctor was not furnished complete medical records; however, it gave more weight to the company doctor’s evaluation in light of the extensive monitoring done.

Ultimately, the Supreme Court upheld the Court of Appeals’ decision, denying Ledesma’s claim for permanent total disability benefits due to the lack of substantial evidence linking his illnesses to his work as a seafarer. The Court underscored that while it adheres to the principle of liberality in favor of seafarers, it cannot grant compensation based on mere surmises or speculation. The decision serves as a reminder that seafarers must provide concrete evidence to support their claims for disability benefits.

On a final note, the court recommended a policy similar to the NLRC when it comes to referral to a third doctor. The court recommended that voluntary arbitrators create a mandated period in order to finally determine the entitlement of seafarers to disability benefits.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer provided enough evidence to prove his illnesses were caused or aggravated by his work conditions to qualify for disability benefits. The Court emphasized that merely listing an illness in the POEA-SEC is not enough.
What does the POEA-SEC say about work-related illnesses?	The POEA-SEC defines a work-related illness as any sickness resulting from an occupational disease listed in Section 32-A of the contract, with the conditions set therein satisfied. Illnesses not listed are disputably presumed as work-related, but this requires substantial evidence to support the claim.
What evidence did the seafarer provide to support his claim?	The seafarer argued that his hypertension was work-related due to the unhealthy diet aboard the vessel. However, the Court found this insufficient, as he did not provide credible evidence linking his diet to his condition.
What did the company-designated physician say about the seafarer’s condition?	The company-designated physician stated that the seafarer’s conditions were not work-related or work-aggravated. They cited familial history and lifestyle factors as potential causes.
What happens when there are conflicting medical opinions?	The POEA-SEC provides a mechanism for resolving conflicting medical opinions by consulting a third doctor jointly agreed upon by the employer and seafarer. The third doctor’s decision is final and binding.
Is the seafarer required to provide a medical report when requesting a third doctor?	No, the seafarer is not required to attach the medical report of his or her own doctor when requesting a referral to a third doctor. It is enough for the seafarer’s letter to show the assessment of fitness to work.
What if the employer fails to act on the request for a third doctor?	If the employer fails to act on the request, the labor tribunals and courts are empowered to conduct their own assessment to resolve the conflicting medical opinions based on the totality of evidence. The employer cannot then claim the company doctor’s opinion is conclusive.
What was the Court’s final decision in this case?	The Supreme Court denied the seafarer’s claim for permanent total disability benefits. The Court emphasized that while it adheres to the principle of liberality in favor of seafarers, it cannot grant compensation based on mere surmises or speculation.

This case underscores the importance of providing substantial evidence when claiming disability benefits as a seafarer. It also highlights the procedural steps for resolving medical disputes and the responsibilities of both seafarers and employers in this process. Moving forward, this ruling helps clarify the evidentiary requirements and the need for a clear link between a seafarer’s work and their medical condition to secure disability compensation.

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: RAEGAR B. LEDESMA VS. C.F. SHARP CREW MANAGEMENT, INC., G.R. No. 241067, October 05, 2022