6/14/2021 E-Library - Information At Your Fingertips: Printer Friendly nothing more than a summary examination of the seafarer's physiological condition and is just enough for the employer to determine his fitness for the nature of the work for which he is to be employed.[23] Since it is not exploratory, its failure to reveal or uncover Utanes' ailments cannot shield him from the consequences of his deliberate concealment[24] The "fit to work" declaration in the PEME cannot be a conclusive proof to show that he was free from any ailment prior to his deployment.[25] We reiterate the application provision of the POEA-SEC, to wit: SECTION 20. COMPENSATION AND BENEFITS xxxx E. A seafarer who knowingly conceals a pre-existing illness or condition in the Pre-Employment Medical Examination (PEME) shall be liable for misrepresentation and shall be disqualified from any compensation and benefits. This is likewise a just cause for termination of employment and imposition of appropriate administrative sactions. Here, Utanes' willful concealment of vital information in his PEME disqualifies him from claiming disability benefits. The Court on many occasions disqualified seafarers from claiming disability benefits on account of fraudulent misrepresentation arising from their concealment of a pre­existing medical condition.[26] This case is not an exception. For knowingly concealing his history of coronary artery disease during the PEME, Utanes committed fraudulent misrepresentation which unconditionally bars his right to receive any disability compensation from petitioners.[27] Nevertheless, even if we were to disregard Utanes' fraudulent misrepresentation, his claim will still fail. Indeed, coronary artery disease, which is subsumed under cardiovascular disease, and hypertension are listed as occupational diseases under Section 32-A, paragraph 11 of the POEA-SEC. However, before Utanes could be benefited, it is required that any of the following conditions be satisfied:[28] a. If the heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by an unusual strain by reasons of the nature of his work b. The strain of work that brings about an acute attack must be sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship c. If a person who was apparently asymptomatic before being subjected to strain at work showed signs and symptoms of cardiac injury during the performance of his work and such symptoms and signs persisted, it is reasonable to claim a causal relationship https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66745 4/9