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The LA granted in part Ravena's complaint in the decision dated May 26, 2008.[15] She ordered the
petitioners to pay Ravena the amount of US$125,000.00, as disability benefits, and US$12,500.00, as
attorney's fees. She, however, denied Ravena's claim for medical reimbursement and sickness benefits as
the petitioners had settled them in full.
In granting Ravena's claim for disability benefits, the LA ruled that Ravena did not need to establish causal
connection between his work and his illness. She pointed out that as 4th Engineer, Ravena was responsible
for the operation, troubleshooting, repair and maintenance of shipboard engines and other machinery of the
vessel. Ravena had to maintain a high degree of alertness at all times and was constantly exposed to
different weather conditions.
The combination of physical, mental and emotional pressure and strain to which Ravena was exposed, led
the LA to conclude that Ravena had increased his risk of contracting the illness. The LA thus further
concluded that Ravena's illness was caused and aggravated by the conditions present in his job during his
employment with the petitioners. To arrive at these conclusions, the LA gave weight to the St. Paul Hospital
medical certificate that Ravena presented, over that of Dr. Cruz which he regarded as self-serving and
biased.
The NLRC's ruling
In its June 30, 2009 decision,[16] the NLRC reversed and set aside the LA's judgment and dismissed
Ravena's complaint for lack of merit.
According to the NLRC, Ravena failed to prove, by substantial evidence, that his illness was work-related,
particularly in the light of the certification issued by Dr. Cruz that his illness - adenocarcinoma of the
ampullary area - was not work-related. To the NLRC, aside from his bare allegations that “exposure to
various substances over the years caused his disease,” Ravena did not present any evidence to prove that
indeed his illness was either work-related or work-aggravated. That he contracted the illness during his
employment contract does not automatically translate to its work-relatedness.
The NLRC denied Ravena's motion for reconsideration[17] in its resolution dated January 18, 2010.[18]
Ravena elevated the case to the CA via a petition for certiorari.[19]
The CA's ruling
In its November 11, 2011 decision,[20] the CA granted Ravena's petition; it reinstated the May 26, 2008
decision of the LA but reduced the disability benefit award from US$125,000.00 to US$60,000.00.
The CA agreed with the LA that to be entitled to disability benefits under the 2000 POEA-SEC, the seafarer
only needs to show that his work and/or his working conditions contributed, even in a small degree, to the
development or aggravation of his disease. In Ravena's case, he reasonably proved that his working
conditions exposed him to factors that aggravated his medical condition. The CA pointed out that while the
possible causes of his condition - cancer of the ampullary area which is a type of pancreatic cancer - are
poorly understood, experts have advised that to prevent its growth, avoiding fatty foods and maintaining a
well-balanced diet rich in fruits and vegetables help.
Relying on the Court's ruling in Leonis Navigation Co., Inc. v. Villamater,[21] the CA noted that in his Answer
(to the petitioners' Memorandum on Appeal) and the Motion for Reconsideration before the NLRC, Ravena
argued, among others, that the food on board M/V Tate J, consisted mainly of frozen red meat and
processed food, all of which contributed to the risk of contracting or aggravating his illness. The petitioners
never controverted this allegation. Although Ravena raised this argument only in the petitioners' appeal
before the NLRC, it should have been and may still be properly admitted in the interest of substantial
justice. Thus to the CA, while his adenocarcinoma of the ampullary area is a non-occupational disease per
the POEA-SEC, Ravena is nevertheless entitled to full disability benefits.
The CA, however, noted that the records do not support the US$125,000.00 that the LA awarded as
disability benefits; the AMOSUP/IMEC TCCC CBA for 2006-2007 submitted by the petitioners in fact support
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