### Facts:
The case involves Jesus B. Barraquio (respondent) against Virjen Shipping Corporation, Capt. Renato Morente, and Odyssey Maritime PTE. Ltd. (petitioners), concerning claims for sickness allowance, disability benefits, moral damages, exemplary damages, and attorney’s fees. Barraquio, hired as chief cook aboard M/T Golden Progress under a 10-month contract initiated on February 29, 2000, fell ill and eventually resigned citing poor health. The procedural journey of this case saw a complaint filed by Barraquio on August 1, 2001, after his resignation and repatriation. The Labor Arbiter ruled in favor of Barraquio, a decision reversed by the National Labor Relations Commission (NLRC). However, the Court of Appeals later reinstated the Labor Arbiter’s decision, prompting the petitioners to bring the matter before the Supreme Court.
### Issues:
1. Whether Barraquio’s resignation was voluntary and thus disentitles him from claiming monetary benefits.
2. Whether hypertension and the suspected ischemic heart disease Barraquio suffered from were developed while onboard, making it compensable under the Standard Employment Contract.
3. Whether Barraquio complied with the post-employment medical examination required under the Standard Employment Contract for Seafarers.
### Court’s Decision:
The Supreme Court reversed the Decision of the Court of Appeals, reinstating the NLRC’s ruling. The Court found that Barraquio’s resignation was voluntary, based on the unequivocal terms of his resignation letter and lack of evidence of compulsion. It was determined that ischemic heart disease, a condition mentioned in Barraquio’s medical records, does not develop in a significantly short time, noting Barraquio’s service on the vessel was too brief for such a condition to have been caused by his employment. Lastly, the Court highlighted Barraquio’s failure to undergo a post-employment medical examination by a company-designated physician within the required three-working-day period post-repatriation, which is mandatorily stipulated for claiming benefits under the said contract.
### Doctrine:
The case illustrates the doctrine on voluntary resignation, highlighting that an employee’s resignation is a voluntary act and disassociates him from entitled employment benefits unless compelled or under duress, which must be substantively proven. It also emphasizes the strict compliance required with post-employment medical examination guidelines under the Standard Employment Contract for Seafarers, important for entitlement to disability benefits.
### Class Notes:
– **Voluntary Resignation:** The act must stem from the employee’s own volition without force, threat, or undue influence from the employer.
– **Standard Employment Contract for Seafarers (POEA):** Compliance with post-employment medical examination is crucial for claims relating to medical repatriation benefits, with the examination to be conducted within three working days upon return.
– **Doctrine of Compensability for Work-Related Illness:** For an illness to be compensable, it must be shown that the employment contributed significantly to the development of the illness or that the risk of contracting the illness is increased by the working conditions.
### Historical Background:
This case reflects the complexities and the legal intricacies involved in labor disputes within the maritime industry, particularly concerning issues around health and safety, employment contracts, and repatriation of seafarers. It also delineates the judicial scrutiny applied to claims of work-related illnesses in the adjudication of employee benefits.
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