In a significant ruling, the Supreme Court clarified the requirements for seafarers to receive disability compensation, emphasizing that a direct causal link must be established between the seafarer’s work and the claimed illness. This means that simply having an illness while employed at sea is not enough; the seafarer must provide substantial evidence demonstrating how their specific job duties and working conditions either caused or aggravated their condition. This decision serves as a reminder of the burden of proof placed on seafarers seeking disability benefits, requiring them to meticulously document and demonstrate the work-related nature of their ailments. The Court ultimately reversed the Court of Appeals’ decision, reinstating the NLRC ruling that dismissed the complaint for lack of merit, because there was not enough proof presented for the causal link of the medical ailment.

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海の男の苦しみ: 航海士の病気は本当に仕事が原因なのか？

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This case, Bright Maritime Corporation v. Jerry J. Racela, centered on Jerry Racela, a fitter employed by Bright Maritime Corporation, who sought disability benefits after developing severe aortic regurgitation and undergoing heart surgery while working onboard a vessel. Upon repatriation, the company-designated physician assessed his condition as aortic valve stenosis, but denied disability grading, claiming it was pre-existing or hereditary and thus not work-related. Racela then consulted a private physician who declared him unfit for sea duty with a 50% disability rating.

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The Labor Arbiter (LA) initially ruled in favor of Racela, awarding him total and permanent disability benefits, but the National Labor Relations Commission (NLRC) reversed this decision, finding no substantial evidence to link his heart disease to his work. The Court of Appeals (CA), however, sided with Racela, deeming his illness work-related based on the fact that he passed his pre-employment medical examination (PEME) and the harsh conditions typically faced by seafarers. Ultimately, the Supreme Court reversed the CA’s decision.

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The Supreme Court emphasized that entitlement to disability benefits under the POEA-SEC requires demonstrating a causal connection between the seafarer’s illness or injury and their contracted work. Citing the 2010 POEA-SEC, the Court noted that while cardiovascular diseases are listed as occupational diseases, compensation is contingent on meeting specific conditions outlined in Section 32-A(11). These conditions include evidence that a pre-existing heart disease was acutely exacerbated by unusual work-related strain, or that the work strain was severe enough to cause cardiac injury within 24 hours, and there was also negligence found on the part of the sea farer.

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In Racela’s case, the Court found a lack of substantial evidence demonstrating that his work as a fitter involved “unusual strain” that triggered or aggravated his heart condition. Crucially, the CA itself conceded that the records lacked any showing of how Racela’s work caused or contributed to his illness. The court underscored the necessity of demonstrating work-relation to establish liability, this must meet Section 32-A requirements.

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Moreover, the Court rejected the CA’s reliance on generalized notions of harsh seafarer conditions and presumptions about the employer’s failure to present certain evidence. Quoting Loadstar International Shipping, Inc. v. Yamson, et al., the Court reiterated that disability claims cannot rest on speculations, presumptions, and conjectures. Instead, labor cases require substantial evidence – relevant evidence a reasonable mind might accept as adequate to support a conclusion.

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Furthermore, the High Court went on to point out a previous court case that tackled an ailment from being an occupational disease. It failed to prove that a reasonable causal relationship existed between their sickness and the work for which they were hired. According to the High Court the labor court must define their actual employment, their ailment’s qualities, and other things that could support the idea that they were hurt on the job.

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The Supreme Court further explained a lack of actual demonstration. Neither did he show how hard it was for his work to hurt him. They determined the cause-and-effect relationship between the sickness and the work couldn’t be proved because it wasn’t clear to the labor court how a seafarer functions or what causes their condition.

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What was the key issue in this case?	The central issue was whether Jerry Racela was entitled to disability compensation under the POEA-SEC, specifically if there was sufficient evidence to establish a causal link between his heart condition and his work as a fitter onboard a vessel.
What is the POEA-SEC?	The POEA-SEC refers to the Philippine Overseas Employment Administration Standard Employment Contract, which sets the terms and conditions for Filipino seafarers working on international vessels, including provisions for disability compensation.
What does ‘work-related illness’ mean under POEA-SEC?	Under the POEA-SEC, a ‘work-related illness’ is any sickness resulting from an occupational disease listed in Section 32-A, provided the specified conditions for that disease are met, such as a causal link between the work and the illness.
What are the conditions for cardiovascular disease to be compensable under the POEA-SEC?	To be compensable, the seafarer must demonstrate that their cardiovascular disease developed under specific conditions outlined in Section 32-A(11) of the POEA-SEC, such as acute exacerbation due to unusual work strain or symptoms manifesting during work performance.
What kind of evidence is needed to prove a work-related illness?	Substantial evidence is required, meaning relevant evidence that a reasonable mind might accept as adequate to support a conclusion. This could include medical records, expert testimonies, and documentation of work duties and conditions.
Why was the CA’s decision reversed in this case?	The CA’s decision was reversed because it relied on generalized statements and presumptions, failing to identify specific evidence demonstrating how Racela’s work as a fitter caused or aggravated his heart condition.
What is the significance of the PEME?	The Pre-Employment Medical Examination (PEME) can show existing conditions when hired, or any underlying symptoms that can potentially bar from working. However, that does not determine compensability.
What should seafarers do to protect their rights?	Seafarers should meticulously document their work duties, conditions, and any health issues that arise during their employment. They should also seek expert medical advice and legal counsel to understand their rights and obligations under the POEA-SEC.
Is passing the pre-employment medical enough for compensability?	No, even a passing grade in pre-employment medical examinations is insufficient for demonstrating whether or not their job affected their existing condition.

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In conclusion, this ruling underscores the critical need for seafarers to provide concrete evidence establishing the link between their work and their illnesses. While the POEA-SEC aims to protect seafarers, claims for disability compensation must be substantiated by substantial proof, rather than mere assumptions or generalized arguments, and has to prove all four condition of section 32-A to be considered as occupational. This would therefore require seafarers to be mindful when taking their employment that they are protecting their rights in case of such situations.

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For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

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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: BRIGHT MARITIME CORPORATION VS. JERRY J. RACELA, G.R. No. 239390, June 03, 2019