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The foregoing facts, coupled with Joselito’s failing health, negate his voluntariness in
executing his complaints, motions to dismiss, and release documents and give life to
the truism that “necessitous men are not, truly speaking, free men; but to answer a
present emergency, will submit to any terms that the crafty may impose upon
them.”[55] Besides, as a rule, quitclaims, waivers, or releases are looked upon with
disfavor and are largely ineffective to bar recovery of the full measure of a worker’s
rights, and the acceptance of benefits therefrom does not amount to estoppel.[56] This
is especially true in this case where instead of promoting the orderly settlement of
disputes; petitioners’ acts encouraged the circumvention of the proper legal procedures
and the evasion of the payment of legitimate claims to a seafarer succumbing to a lifethreatening disease. Therefore the settlements that Joselito entered into must be
struck down for being contrary to public policy.
Lastly, despite the declaration of fitness that would have entitled him to reinstatement
to his former position,[57] Joselito was not provided work, apparently due to his
worsening health. He was thus constrained to seek medical attention at his own
expense and was continuously unable to work until his death. This only shows that his
medical condition effectively barred his chances of being hired by other maritime
employers and deployed abroad on an ocean-going vessel. In a number of cases, the
Court disregarded the medical report issued by the company designated physician that
the seafarer was fit to work in view of the evidence on record that the latter had in fact
been unable to engage in his regular work within the allowable period,[58] as in this
case.
In view of the foregoing, Joselito’s death is compensable for having been caused by an
illness duly established to have been contracted in the course of his employment.
WHEREFORE, the petition is DENIED. The October 21, 2011 Decision dated and
March 27, 2012 Resolution of the Court of Appeals in CA-G.R. SP No. 113342 are
hereby AFFIRMED. Therefore, petitioners Inter-Orient Maritime, Incorporated and/or
Tankoil Carriers, Limited are ordered to pay respondent Cristina Candava the following
amounts: (1) US$50,000.00 as death benefits; (2) US$7,000.00 as benefits to
Joselito’s minor child, Jerome Lester; (3) US$1,000.00 as burial assistance; and (4) ten
percent (10%) of the total monetary award as attorney’s fees.
SO ORDERED.
Carpio, (Chairperson), Brion, Del Castillo, and Perez, JJ., concur.
[1] Rollo, pp. 35-62.
[2] Id. at 70-86. Penned by Associate Justice Ricardo R. Rosario, with Associate Justices
Hakim S. Abdulwahid and Danton Q. Bueser, concurring.
[3] Id. at 106-107.
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