Case Digest: Villanueva v. Baliwag Navigation

G.R. No. 206505: July 24, 2013




On May 13, 2003, Villanueva entered into a ten-month employment contract with the respondents as bosun for the vessel M/S Forestal Gaia. After his pre-employment medical examination (PEME) on July 28, 2003, he was declared fit to work, although the PEME report indicated that he had a heart disease. Villanueva joined the vessel M/S Forestal Gaia on August 17, 2003. Villanueva alleged that while in the performance of his duties on board the vessel one day, he suddenly felt pain in his chest and experienced difficulty in breathing. He asked for medical assistance but was given only oral medication to alleviate the pain. He was repatriated on June 24, 2004 upon the expiration of his contract.

On Villanuevas return to the Philippines, he allegedly reported to the agency and asked for a medical check-up, but was only referred to the Centerpoint Medical Services (Centerpoint) after several follow-ups. Centerpoint traced his medical history showing that he had a heart disease and declared him unfit to work. The declaration prompted him to ask for sickness allowance and disability benefits from the respondents but his requests were all denied.

At this point, he sought a second opinion from an internist-cardiologist who confirmed that he had a heart disease and declared him unfit for sea duty; he was given a Grade 1 disability rating. On this basis, he filed a formal claim for disability benefits against the respondents. The respondents denied liability, contending that Villanueva was repatriated not for medical reasons, but for the completion of his contract.

The LA dismissed the complaint for lack of merit, declaring that Villanuevas heart ailment is not compensable as it was not work-related. NLRC affirmed the LAs decision and denied petitioners motion for reconsideration. Villanueva filed a petition for certiorari before the CA sustained the NLRC ruling. He filed a motion for reconsideration but the same was denied. Hence, this petition.

ISSUE: Whether or not Villanueva is entitled to the benefits


Labor Law

The CA brushed off Villanuevas submission that his heart ailment, which he allegedly contracted during his almost twenty (20) years of employment with the respondents, was aggravated by his work on board the vessel M/S Forestal Gaia. While the CA acknowledged that under Section 32-A(11) of the 2000 POEA-Standard Employment Contract, an aggravation would make his claimed heart ailment an occupational disease, no substantial evidence supported this situation.

Further, the CA stressed that the fact that Villanueva was repatriated for finished contract and not for medical reasons weakened, if not belied, his claim of illness on board the vessel. Lastly, the CA found that Villanueva failed to comply with the mandatory three-day post-employment medical examination under Section 20(B)(3) of the 2000 POEA-Standard Employment Contract, contrary to his claim that he reported to the agency upon his repatriation and asked for a medical check-up but was refused.

The SC find no reversible legal error in the CA ruling affirming the denial of Villanuevas claim for disability benefits. We find it undisputed that he was repatriated for finished contract, not for medical reasons. More importantly, while the 2000 POEA-Standard Employment Contract (Section 32-A11) considers a heart disease as occupational, Villanueva failed to satisfy by substantial evidence the condition laid down in the Contract that if the heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain brought about by the nature of his work.

Clearly, as the CA emphasized, Villanueva's repatriation for completion of his contract belies his submission that his claimed heart disease had been aggravated by his work on board the vessel MIS Forestal Gaia.