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agreed pretermination to mean that the seafarer had contracted illness aboard the
ship. In contrast, respondent can only rely on the element of proximity to deduce that
Armando suffered the fatal illness during his service.
Secondly, neither the LA nor the NLRC made a factual determination of Armando’s
actual work as an Able Seaman. Respondent’s website definition of an Able Seaman
was not even recognized in the NLRC Decision. Hence, at the level of the labor
tribunals, there was already no premise on which to base the conclusion that
Armando’s work involved considerable exposure to the risks of contracting lung cancer.
Nevertheless, on certiorari, the CA held that there was a reasonable connection
between the job of Armando and his lung disease. It even stated that it was
undisputed[35] that he had worked in the cargo section of the vessel.
The CA’s appreciation is manifestly erroneous. A plain reading of the pleadings on
record will easily reveal that the parties vehemently contested the actual job
description of Armando. Petitioners claimed that he worked with the deck contingent,
while respondent asserted that he was assigned to the ship’s cargo. These conflicting
contentions were not resolved by either the LA or the NLRC. Therefore, since the CA
proceeded from a disputed and unresolved factual claim, its resulting inference on the
work connection may be disregarded. Indeed, no ruling shall be rendered by any court
without clearly and distinctly stating therein the facts on which the ruling is based.[36]
In any event, even if it were proven that Armando worked in the cargo section of the
ship, the CA must still find justification for how his work environment caused his
constant headaches, whether he recovered from his ailment,[37] and how it worsened
into the alleged fatal illness.[38]
This explanation need not show a direct causal connection; but positive propositions[39]
on employment factors like age, position, actual work, dietary provisions,[40] exposure
to substances,[41] and possibility of recovery[42] have been considered by the Court as
adequate in compensation proceedings. In this instance, the NLRC and the CA failed to
discuss the employment conditions that had led to the ailment of Armando.
Thirdly, for respondents to be entitled to death benefits under Section 32-A of the POEA
Contract, the CA must further find that the alleged work- related illness of Armando
caused his death.
At most, based on the allegations of respondent, Armando claimed to have suffered
from constant headaches aboard M/V Magellan. However, there was no determination
of the link between his ailment (headaches) and his cause of death (lung cancer). In
Medline Management, Inc. v. Roslinda[43] citing Hermogenes v. OSCO Shipping
Services, Inc.[44] and Gau Sheng Phil., Inc. v. Joaquin,[45] we have discussed death
arising from a seafarer’s illness in this wise:
Indeed, the death of a seaman several months after his repatriation for
illness does not necessarily mean that: (a) the seaman died of the same
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