CASE DIGEST : BW SHIPPING PHILIPPINES v. MARIO H. ONG GR No. 202177 GAERLAN

 FACTS : The petition for review on certiorari is grounded on the contention that the Court of Appeals (CA) erred in affirming the National Labor Relations Commission’s (NLRC) rulings granting respondent permanent total disability benefits. The factual backdrop shows that respondent, a seafarer employed by petitioner BW Shipping Philippines, Inc., developed uncontrolled diabetes and hypertension while on duty, prompting repatriation and subsequent medical treatment. Despite company-designated physicians declaring him fit to resume sea duties, respondent’s own medical evaluation confirmed persistent illness, rendering him unable to return to work. The Labor Arbiter awarded permanent total disability benefits, which the NLRC affirmed, emphasizing that the illness was work-connected and occurred during the contract term. The CA upheld these findings, recognizing that respondent’s inability to perform his duties despite the fitness certification, combined with medical proof of work-related illness, entitled him to compensation. Petitioners’ claim that the CA gravely abused its discretion is unmeritorious, as the findings of the labor tribunals on the compensability of the respondent’s disability, being factual and supported by substantial evidence, are binding and cannot be overturned on certiorari absent a showing of grave abuse of discretion amounting to lack or excess of jurisdiction.

ISSUE : WON the CA is correct

HELD : The petition for review on certiorari is GRANTED. The Court holds that the respondent, Mario H. Ong, failed to establish entitlement to permanent total disability benefits, as his claims of diabetes mellitus and essential hypertension were not proven to be work-related or of such severity as to cause permanent incapacity under Section 20(B), paragraph 6, and Section 32-A of the 2000 POEA Standard Employment Contract (POEA-SEC). The Court emphasized that diabetes is generally a metabolic and familial condition not typically caused by occupational duties, while essential hypertension, though recognized as an occupational disease, must impair bodily functions to a degree constituting permanent disability—a showing absent in the present case. Respondent’s contention was further undermined by the credible medical findings of company-designated physicians who treated him immediately after repatriation and certified him fit to resume sea duties, supported by normal laboratory results. Respondent also failed to follow the POEA-SEC-mandated procedure to resolve conflicting medical assessments with a third mutually agreed-upon physician. Consequently, the Court found that the CA did not correctly determine the absence of grave abuse of discretion by the NLRC in granting the benefits, as the award was not supported by substantial evidence. The CA decision dated March 9, 2012, and its Resolution dated June 4, 2012, are REVERSED and SET ASIDE, and respondent’s complaint is DISMISSED.