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STATUS MARITIME CORPORATION v. RODRIGO C. DOCTOLERO

FACTS:

Petitioners Status Maritime Corporation and Admibros Shipmanagement Co., Ltd. and respondent Rodrigo C. Doctolero are parties in the case. Doctolero was hired as Chief Officer on board the vessel M/V Dimitris Manios II. While in Mexico, Doctolero experienced chest and abdominal pains and was diagnosed with "Esophago-Gastritis-Duodenitis." He paid his own hospital bills and sought assistance from the Philippine Embassy for his repatriation to the Philippines. Doctolero filed a complaint with the NLRC seeking payment of disability benefits, reimbursement of medical expenses, and other damages. The Labor Arbiter dismissed the complaint, while the NLRC affirmed the Labor Arbiter's decision but ordered the petitioners to reimburse Doctolero for his medical expenses. Doctolero's motion for reconsideration was denied. He then filed a petition for certiorari with the CA, which declared his illness as work-related and awarded him disability benefits and other damages.

ISSUES:

  1. Whether Doctolero's illness is work-related.

  2. Whether Doctolero is entitled to disability benefits.

  3. Whether Doctolero is entitled to reimbursement of medical expenses.

  4. Whether Doctolero is entitled to moral and exemplary damages.

RULING:

  1. The CA declared that Doctolero's illness is work-related because it was contracted by him while on board the vessel and he had undergone pre-employment medical examinations declaring him fit to work.

  2. The CA ruled that Doctolero is entitled to disability benefits because he was unable to perform his customary job for more than 120 days.

  3. The CA affirmed the NLRC's ruling that Doctolero is entitled to reimbursement of his medical expenses.

  4. The CA also held that Doctolero is entitled to moral and exemplary damages due to the petitioner's failure to shoulder the expenses Doctolero incurred while awaiting his repatriation.

PRINCIPLES:

  • The employment need not be the sole factor in the growth, development, or acceleration of an illness to entitle the claimant to benefits; it is enough that the employment contributed, even in a small measure, to the development of the disease.

  • A claimant is entitled to disability benefits if he has been unable to perform his customary job for more than 120 days.

  • Reimbursement of medical expenses is proper if the illness was contracted during the term of the employment and there is no contrary evidence to prove that the illness was not work-related.

  • Moral and exemplary damages may be awarded if an employer fails to shoulder the expenses incurred by an employee while awaiting repatriation.