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ocean-going vessel are likely stress factors in the development of
hyperthyroidism irrespective of its origin. As recounted by the respondent in
his position paper, the work on board the MV Star Princess was a strenuous
one. It involved day-to-day activities that brought him under pressure and
strain and exposed him to chemical and other irritants, and his being away
from home and family only aggravated these stresses.[36]
Indeed, Laurel has shown a reasonable causation between his working condition and
his hyperthyroidism contracted during his employment warranting the recovery of
compensation. Settled is the rule that for illness to be compensable, it is not necessary
that the nature of the employment be the sole and only reason for the illness suffered
by the seafarer. It is sufficient that there is a reasonable linkage between the disease
suffered by the employee and his work to lead a rational mind to conclude that his work
may have contributed to the establishment or, at the very least, aggravation of any
pre-existing condition he might have had.[37]
The case of Career Philippines Shipmanagement, Inc. v. Serna[38] may be relevant. In
the said case, the Court sustained the award of disability benefits and held:
The causal connection the petitioners cite is a factual question that we
cannot touch in Rule 45. The factual question is also irrelevant to the 1996
POEA-SEC. In Remigio v. National Labor Relations Commission, we expressly
declared that illnesses need not be shown to be work-related to be
compensable under the 1996 POEA-SEC, which covers all injuries or
illnesses occurring in the lifetime of the employment contract. We contrast
this with the 2000 POEA-SEC which lists the compensable occupational
diseases. Even granting that work-relatedness may be considered in this
case, we fail to see, too, how the idiopathic character of toxic goiter and/or
thyrotoxicosis excuses the petitioners, since it does not negate the
probability, indeed the possibility, that Serna’s toxic goiter was caused by
the undisputed work conditions in the petitioners’ chemical tankers.
(Underscoring supplied)
Moreover, it should be noted that Laurel was not only diagnosed with Graves’ Disease.
Per medical certificate of Dr. Caceres, Laurel’s physician, he was also found to be
suffering from: (1) Stage 1B diffuse goiter;
(2) recurrent periodic paralysis of lower
extremities; (3) Wayne’s Index to 27 points; and (4) hyperthyroid TFT’s (suppressed
TSH, elevated T3). His illness/disability was assessed as equivalent to Grade 1
Impediment. Thus, he was advised “not to undergo strenuous activity, as it may be
very dangerous for him to ambulate with the unpredictable episodes of periodic
paralysis.” Evidently, these illnesses disabled him to continue his job on board the
vessel. Therefore, there is no doubt that under the 2000 POEA-SEC, he is entitled to
disability compensation.
The petitioners cannot successfully invoke the case of Magsaysay Maritime Corp. v.
NLRC[39] to insulate themselves from liability for disability benefits. The said case is not
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