**Madridejos v. NYK-FIL Ship Management, Inc., G.R. No. 205674, 810 Phil. 704 (2019)**
### Facts:
1. **Employment and Incident**:
– Mario C. Madridejos, a Filipino seafarer, was hired by NYK-FIL Ship Management, Inc. (“NYK-FIL”) as a Demi Chef.
– Employment contract signed on March 25, 2010.
– Effective for 10 months, with a monthly salary of USD 1,055.
– April 10, 2010: Commenced work aboard the vessel.
– April 28, 2010: Slipped and fell down hitting his abdomen on a metal pipe. Diagnosed with a sebaceous cyst near the umbilicus.
– Operated on the following day at Spire Southampton Hospital, England.
2. **Termination and Repatriation**:
– July 5, 2010: Madridejos was terminated within the probationary period. Notice mentioned termination pursuant to Item No. 7 of Employment Agreement.
– July 6, 2010: Madridejos was repatriated to the Philippines.
3. **Medical Follow-ups and Complaint**:
– July 7, 2010: Allegedly reported to NYK-FIL for medical referral but was denied.
– Examined by Dr. Aylmer F. Españo and later by Dr. Eduardo Yu. Both concluded permanent unfitness for sea service due to the cyst.
– Filed complaint before the Labor Arbiter for disability benefits.
4. **Procedural Posture**:
– **Labor Arbiter Decision (August 11, 2011)**: Awarded Grade 7 Disability benefits to Madridejos.
– **National Labor Relations Commission (NLRC) Decision (March 30, 2012)**: Reversed Labor Arbiter’s decision; dismissed the complaint.
– **Court of Appeals Decision (September 26, 2012)**: Affirmed NLRC’s decision.
– **Supreme Court Petition for Review**: Filed by Madridejos, alleging grave abuse of discretion by NLRC.
### Issues:
1. **Entitlement to Disability Benefits**:
– Whether Madridejos is entitled to disability benefits despite the termination being cited as contractual and not due to his cyst.
2. **Work-relatedness of the Illness**:
– Whether the sebaceous cyst was work-related and thus compensable under the Philippine Overseas Employment Administration (POEA) contract.
### Court’s Decision:
1. **Termination Validity**:
– Supreme Court upheld the factual findings, confirming Madridejos’ termination was within terms of the employment contract as probationary. Therefore, the termination was valid and not due to medical repatriation.
2. **Non-compensability of Sebaceous Cyst**:
– Sebaceous cyst not classified as work-related under Section 32-A of the POEA contract.
– Disconnection between Madridejos’ job duties and the development of the cyst.
– Discharge letter did not recommend further treatment in the Philippines beyond the minor operation received in England.
– Petitioner’s silent period post-surgery until repatriation bolsters non-relation to job environment.
3. **Lack of Substantial Evidence**:
– Claim required more than presumptive evidence; lacked substantial evidence of work-relatedness or aggravation due to employment.
### Doctrine:
– **Work-related Illness Presumption**:
– Illnesses not listed under Section 32 of the POEA contract are presumed work-related, but claimants must substantiate this presumption with sufficient evidence linking illness to employment.
### Class Notes:
1. **Key Elements and Legal Principles**:
– **Probationary Employment**: Valid termination during probation does not entitle employee to disability benefits unless clear connection to job is shown.
– **Notarious Negligence & Proof of Work-relatedness**:
– Illness must be proven to be contracted during and due to the job environment under POEA standards.
2. **Statutory Provisions**:
– **POEA Memorandum Circular No. 9, Section 20(B)**:
– Employer’s liabilities related to work-incurred injuries/illnesses.
– Substantial evidence needed beyond presumptive work-relatedness.
### Historical Background:
– **Labor Protection Legislation**:
– Reflects robust legal principles protecting Filipino overseas workers, emphasizing the burden on employees to prove work-relatedness of their illnesses.
– Context of increased judicial scrutiny in employment contracts for seafarers owing to the global maritime industry dynamics.
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