TL;DR

The Supreme Court ruled in favor of seafarer Rodelio R. Onia, granting him total and permanent disability benefits. The Court clarified that if a company-designated physician fails to issue a final and definite disability assessment within the legally prescribed periods (120 days, extendable to 240), the seafarer’s disability is automatically considered total and permanent. Furthermore, the Court emphasized that cerebrovascular events and hypertension are presumed work-related for seafarers under the POEA-SEC, shifting the burden to employers to disprove this connection. This decision reinforces the protection afforded to seafarers, ensuring they receive just compensation for work-related illnesses when employers fail to fulfill their obligations in providing timely and conclusive medical assessments.

Stroke at Sea: Upholding Seafarer’s Right to Disability Benefits Amidst Incomplete Medical Assessments

This case, Rodelio R. Onia v. Leonis Navigation Company, Inc., revolves around the claim of a seafarer, Rodelio R. Onia, for total and permanent disability benefits after suffering a stroke while working onboard a vessel. The central legal question is whether Onia is entitled to these benefits despite the company’s arguments of concealment of pre-existing conditions and the alleged non-work-related nature of his illness. The Supreme Court’s decision clarifies critical aspects of seafarer disability claims, particularly concerning the presumption of work-relatedness for certain illnesses and the employer’s responsibility to provide a final and definite medical assessment.

The factual backdrop involves Onia’s employment as an oiler. Prior to deployment, he was declared “fit for sea duty” despite a pre-employment medical examination (PEME) revealing pre-existing hypertension and diabetes, for which maintenance medications were prescribed. While at sea, Onia suffered a stroke and was medically repatriated. Upon returning to the Philippines, he was diagnosed with “Cerebrovascular infarct, Left Pons, Hypertensive Cardiovascular Disease and Diabetes Mellitus.” The company-designated physician issued a medical report but failed to provide a final disability assessment. Consequently, Onia sought disability benefits, which were initially granted by the Labor Arbiter (LA) but later denied by the National Labor Relations Commission (NLRC) and the Court of Appeals (CA). The NLRC and CA reasoned that Onia’s illness was not proven to be work-related and that he had concealed his pre-existing conditions.

The Supreme Court, however, reversed the CA and NLRC decisions, finding in favor of Onia. The Court first addressed the issue of concealment, stating that Onia’s pre-existing conditions were discoverable during the PEME and were in fact known to the company physician, who still declared him fit for duty and prescribed medication. Therefore, the defense of concealment was deemed untenable. Building on this point, the Court then tackled the crucial aspect of work-relatedness. It emphasized that under the 2010 POEA-SEC, cerebrovascular events and end-organ damage from hypertension are listed as occupational diseases, thus carrying a presumption of work-relatedness. The Court stated:

It should be stressed that petitioner’s diagnosed illnesses of “Cerebrovascular infarct, Left Pons, Hypertensive Cardiovascular Disease and Diabetes Mellitus” are presumed to be work-related, since these are listed under Section 32-A (Occupational Diseases) of the 2010 POEA-SEC. Particularly, they are listed under paragraphs 12 and 13, respectively referring to “Cerebro-vascular events” and “End Organ Damage Resulting from Uncontrolled Hypertension.”

The Court highlighted the demanding nature of Onia’s work as an oiler, which exposed him to fluctuating temperatures, engine fumes, and chemicals, contributing to or aggravating his pre-existing conditions. Crucially, the Court pointed out that Onia experienced stroke symptoms while performing his duties, establishing a clear link between his work and his illness. Even if the illness pre-existed, the Court reiterated that aggravation due to working conditions warrants compensation.

A pivotal aspect of the ruling is the emphasis on the company-designated physician’s duty to provide a final and definite disability assessment within 120 days, extendable to 240 days. The Court noted that in Onia’s case, the medical report issued by the company physician, while within the prescribed period, lacked a definitive disability assessment. It merely described risk factors and stated the illness was not work-related, failing to specify the degree of disability or fitness to work. The Supreme Court underscored the importance of a complete and definite assessment, stating:

Notably, the responsibility of the company-designated physician to come up with a final and definite assessment within the foregoing prescribed periods demands that the disability rating be properly reflected in a formal medical report. On this score, it is well-established that, to be deemed valid, this assessment must be complete and definite; otherwise, the medical report shall be set aside and the disability grading contained therein rendered invalid. In this instance, where the precise medical status of the seafarer’s disability remains unresolved, the law steps in and deems the same as total and permanent.

Because of this lack of a final and definite assessment, the Court concluded that Onia’s disability should be considered total and permanent by operation of law, entitling him to disability benefits. The Court reinstated the Labor Arbiter’s decision, awarding Onia US$60,000 in disability benefits and attorney’s fees, while removing the awards for moral and exemplary damages due to lack of evidence of bad faith. This ruling serves as a significant reminder of the procedural and substantive rights of seafarers in disability claims. It reinforces the presumption of work-relatedness for listed illnesses and strictly construes the employer’s obligation to ensure timely and comprehensive medical assessments by company-designated physicians. The decision underscores the pro-labor stance of Philippine jurisprudence, prioritizing the protection and welfare of seafarers.

FAQs

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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: Onia v. Leonis Navigation Company, Inc., G.R No. 256878, February 14, 2022