4/20/2021
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THIRD DIVISION
[ G.R. No. 234711, March 02, 2020 ]
DAISY REE CASTILLON, JUREEZE PHOEBE CASTILLON, AND DREW
WYATT CASTILLON, PETITIONERS, VS. MAGSAYSAY MITSUI OSK
MARINE, INC. AND/OR FRANCISCO D. MENOR AND/OR MOL SHIP
MANAGEMENT CO., LTD., RESPONDENTS.
DECISION
LEONEN, J.:
In resolving claims under the Philippine Overseas Employment Administration Standard
Employment Contract, the element of work-relatedness only demands a reasonable link
between the illness and the seafarer's work. It is not required that the seafarer's work
is the sole contributor or factor in the aggravation of the illness. The test is only
reasonable proof of work-connection, and not direct causation.
This resolves a Petition for Review on Certiorari[1] assailing the Decision[2] and
Resolution[3] of the Court of Appeals. The Court of Appeals dismissed the petition and
ruled that Junlou H. Castillon's illness and subsequent death is not compensable under
the Philippine Overseas Employment Administration Standard Employment Contract.
Junlou H. Castillon (Castillon) was employed by Magsaysay Mitsui Osk Marine, Inc.
(Magsaysay) as an Able Seaman for nine (9) months with a basic salary of US$564.00.
He underwent pre-employment medical examination and was declared fit to work. On
February 23, 2009, he was deployed on board M/V Amethyst Ace.[4]
In June 2009, Castillon complained of intermittent mild stomach pains but he later
dismissed them as ordinary discomfort.[5]
However, in August 2009, his stomach ache became severe and he discovered blood in
his stool. While they were in Japan, a doctor examined him, declared him unfit for duty,
and recommended his repatriation. The doctor further recommended laboratory tests to
rule out malignancy due to Castillon's record of chronic hemorrhage and family history
of intestinal malignancy.[6]
On September 3, 2009, Castillon was repatriated to the Philippines. He reported his
condition to Magsaysay, which then referred him to Medicross Health Management
Hospital where he was diagnosed with abdominal mass and was recommended to
undergo colonoscopy. The company-designated physician likewise determined that
Castillon's condition "was not work-related."[7]
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