Case Digest: Magsaysay Maritime v. Laurel

G.R. No. 195518 : March 20, 2013




Respondent Earlwin Meinrad Antero F. Laurel (Laurel) was employed by petitioner Princess Cruise Lines, Ltd., through its local manning agency, petitioner Magsaysay Maritime Corporation, as second pastryman on board the M/V Star Princess. In the course of the voyage, Laurel fell ill. He complained of fever with cough, and he was given paracetamol until reaching the shore. On April 3, 2005, he disembarked from the vessel and proceeded to a hospital in Florida, U.S.A. Due to the persistence of his illness, he was repatriated for further evaluation. He arrived in the Philippines on April 7, 2005.

Laurel was admitted to the Metropolitan Hospital in Manila, placed under the medical care of Dr. Robert Lim, and diagnosed with upper respiratory tract infection and hyperthyroidism. He was discharged on April 11, 2005 and was prescribed take-home medications. It was indicated in the said medical report that hyperthyroidism, an overactivity of the thyroid gland usually secondary to an immunologic reaction, was not work-related.

On April 25, 2005, during his last follow-up at the petitioner companys medical facility, Laurel was already asymptomatic for upper respiratory tract infection. As he no longer had fever, cough and cold, he was cleared of his pulmonary problem. He was advised to consult an internist on his own account with regard to his hyperthyroidism as this illness was allegedly not work-related.

When Laurel returned to his hometown of Naga City, he consulted Dr. Ramon Caceres (Dr. Caceres), an endocrinologist. On January 21, 2006, Dr. Caceres issued a medical certificate attesting that he was treated for Euthyroid Graves Disease. By then, he was clinically and biochemically euthyroid. His oral anti-thyroid medications were tapered off for possible discontinuation of treatment.

On August 3, 2006, Laurel filed a complaint against the petitioners before the NLRC, claiming medical reimbursement, sickness allowance, permanent disability benefits, damages, and attorneys fees. Thereafter, Laurel returned to Dr. Caceres for a more extensive diagnosis. On August 12, 2006, he obtained a medical certificate with these findings Stage 1B diffuse goiter, recurrent periodic paralysis of lower extremities Waynes Index to 27 points, and hyperthyroid TFTs (suppressed TSH, elevated T3).

The petitioners opposed Laurels claims, contending that his illness had been categorically determined as not work-related.The LA held that Laurel was not entitled to his claims, with his hyperthyroidism having been found as not work-related by petitioners company physician.

On appeal, the NLRC reversed the LA decision and awarded disability compensation in favor of Laurel. It found that the illness was work-related for failure of the petitioners to overcome the presumption provided under the POEA-SEC that an illness occurring during the employment, even if not listed, was work-related. On further appeal, the CA sustained the NLRC decision. Petitioners filed a motion for reconsideration but the same was denied. Hence, this petition.

ISSUE: Whether or not the CA erred in sustaining the NLRC decision

HELD: No. CA decision affirmed.

Labor Law

Two elements must concur for an injury or illness of a seafarer to be compensable. First, the injury or illness must be work-related; and second, that the work-related injury or illness must have existed during the term of the seafarers employment contract.

As borne by the records, Laurel was afflicted with hyperthyroidism during the term of his employment contract that caused his discharge for medical examination in Florida, U.S.A. on April 3, 2005 and his subsequent repatriation to the Philippines.

The most common underlying cause of hyperthyroidism is Graves' Disease. It is classified as an autoimmune disease, caused by the patient's own immune system turning against the patient's own thyroid gland. The hyperthyroidism of Graves' Disease, therefore, is caused by antibodies that the patient's immune system makes. The antibodies attach to specific activating sites on the thyroid gland and those, in turn, cause the thyroid to make more hormones.

Given the foregoing, although Graves Disease is attributed to genetic influence, the Court finds a reasonable work connection between Laurels condition at work as pastryman (cook) and the development of his hyperthyroidism. His constant exposure to hazards such as chemicals and the varying temperature, like the heat in the kitchen of the vessel and the coldness outside, coupled by stressful tasks in his employment caused, or at least aggravated, his illness. It is already recognized that any kind of work or labor produces stress and strain normally resulting in wear and tear of the human body.

Indeed, Laurel has shown a reasonable causation between his working condition and his hyperthyroidism contracted during his employment warranting the recovery of compensation. Settled is the rule that for illness to be compensable, it is not necessary that the nature of the employment be the sole and only reason for the illness suffered by the seafarer. It is sufficient that there is a reasonable linkage between the disease suffered by the employee and his work to lead a rational mind to conclude that his work may have contributed to the establishment or, at the very least, aggravation of any pre-existing condition he might have had.

Moreover, it should be noted that Laurel was not only diagnosed with Graves Disease. Per medical certificate of Dr. Caceres, Laurels physician, he was also found to be suffering from: (1) Stage 1B diffuse goiter; (2) recurrent periodic paralysis of lower extremities; (3) Waynes Index to 27 points; and (4) hyperthyroid TFTs (suppressed TSH, elevated T3). His illness/disability was assessed as equivalent to Grade 1 Impediment. Thus, he was advised "not to undergo strenuous activity, as it may be very dangerous for him to ambulate with the unpredictable episodes of periodic paralysis." Evidently, these illnesses disabled him to continue his job on board the vessel. Therefore, there is no doubt that under the 2000 POEA-SEC, he is entitled to disability compensation.

In the case at bench, a causal link between Laurels ailment and his working condition was sufficiently established. Other than the specific determination by the attending company doctor that "hyperthyroidism, in which there is overactivity of the thyroid gland, usually secondary to an immunologic reaction, is not work-related,"no further explanation was given to support the conclusion that the illness was indeed not work-related. There was no declaration from the company doctor as regards his fitness to return to work, while he was advised by his own physician to refrain from undergoing strenuous activities.


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