This principle was reiterated in the recent case of Seagull Shipmanagement and
Transport, Inc. v. NLRC.
While indeed, the Labor Codes provisions on disability benefits under the
Employees Compensation Commission (ECC) require the element of workrelation for an illness to be compensable, the 1996 POEA SEC giving a more
liberal provision in favor of the seafarer must apply. As a rule, stipulations in an
employment contract not contrary to statutes, public policy, public order or
morals have the force of law between the contracting parties. In controversies
between a laborer and his master, doubts reasonably arising from the evidence, or
in theinterpretation of agreements and writing should be resolved in
the formers favor. The policy is to extend the doctrine to a greater number of
employees who can avail of the benefits under the law, in consonance with the
avowed policy of the State to give maximum aid and protection of
labor. (Citations omitted)[20]
The aforecited ruling is controlling for it is based on facts and issues that are
strikingly parallel to those obtaining in the present case: both cases involve
Filipino seafarers stricken with coronary artery disease during the terms of their
contracts.
As in Remigio v. National Labor Relations Commission, therefore, we apply
to the present case Section 20-B(5) of the 1996 POEA-SEC as legal basis for the
grant of disability benefits to Cantomayor who was afflicted with coronary artery
disease during the term of his contract. The CA therefore was correct in ruling that
the claim of Cantomayor had legal basis. We must point out, though, that it was
mistaken in citing, not Section 20-B, but Section 32-A. The latter provision
(Section 32-A) can be found only in the 2000 POEA-SEC,[21] which took effect
after the parties entered into their 1998 employment contract.
As to the finding of the LA and NLRC that said ailment was pre-existing,
the same is belied by the result of Cantomayors PEME.