5/19/2021 E-Library - Information At Your Fingertips: Printer Friendly 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 sanctions.[78] (Emphasis supplied) In Philman Marine Agency, Inc. v. Cabanban,[79] it was ruled that the seafarer's failure to disclose any illness or injury that they have knowledge of disqualifies them from claiming disability benefits. In that case, the seafarer filed a claim for disability benefits after being diagnosed with hypertension while onboard the vessel. He asserted that since his pre-employment medical examination was exploratory and showed that he was in good health prior to the employment, his subsequent diagnosis proves that his illness occurred during his employment. In rejecting the compensation claim, the Court in Philman held that the seafarer concealed that he suffered from hypertension and was taking antihypertensive medication prior to his employment, which disqualified him from compensation under the POEA Standard Employment Contract. Second, although Dr. Ranjan of the Fujairah Port Clinic diagnosed Armando with hypertension, Armando did not reveal in his PEME that he had been suffering from this condition and had been taking antihypertensive medications for five years. As the petitioners correctly argued, Armando's concealment of this vital information in his PEME disqualifies him from claiming disability benefits pursuant to Section 20-E of the POEA-SEC[.] We need not belabor this point as a plain reading of the above provision shows that the seafarer's concealment of a pre-existing medical condition disqualifies him from claiming disability benefits. We note that Dr. Ranjan of the Fujairah Port Clinic stated in his report that Armando was a "known case of HT, on atenolol 50 mg OD [for five years]." The import of this statement cannot be disregarded as it directly points to Armando's willful concealment; it also shows that Armando did not acquire hypertension during his employment and is therefore not work-related.[80] Moreover, the Court in Philman ruled that the seafarer cannot capitalize on his clearance in the pre-employment medical examination because it was not exhaustive. Employers are not burdened to discover any and all preexisting medical conditions of the seafarer, thus: Contrary to Armando's contention, the PEME is not sufficiently exhaustive so as to excuse his non-disclosure of his pre-existing hypertension. The PEME is not exploratory and does not allow the employer to discover any and all preexisting medical condition with which the seafarer is suffering and for which he may be presently taking medication. The PEME is nothing more than a summary examination of the seafarer's physiological condition and is just https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66521 11/19