FACTS:

Lloyd was initially employed by Maryville Manila as a seafarer aboard M/V Renuar, which was held hostage by Somali pirates. After being repatriated, Lloyd was re-hired by Maryville Manila but was repatriated again while working on M/V Iron Manolis. He filed a complaint for disability benefits, claiming that he suffered from occupational stress and other work-related disorders. The labor arbiter granted his claim, but the NLRC reversed the decision. Lloyd filed a petition for certiorari with the CA, which reinstated the labor arbiter's decision. Maryville Manila filed a motion for reconsideration but it was denied. They then petitioned the Supreme Court.

Maryville Manila and Maryville Maritime have the burden to establish their claims. The CA misread the rulings in Baron and Barros, which both involved cases of illegal dismissal. In those cases, it was ruled that it is the employer's responsibility to prove the validity of the dismissal.

Note: I did not include the last paragraph because it is a repetition of the ruling already stated above.

ISSUES:

1. Whether the burden of proof lies on the employer to prove that the seafarer's repatriation was not for medical reasons.

2. Whether Lloyd presented substantial evidence to prove that he reported to the company-designated physician after his repatriation.

3. Whether Lloyd is entitled to total and permanent disability benefits under the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC).

4. Which provision of the POEA-SEC applies in this case.

5. Whether Lloyd Espinosa is entitled to total and permanent disability benefits.

6. Whether there is a reasonable link between Lloyd's illnesses and the nature of his work.

RULING:

1. The Supreme Court granted Maryville Manila's petition, stating that the CA erred in evaluating the evidence and in concluding that Lloyd was medically repatriated. The Court clarified that the burden of proof in establishing the reason for repatriation rests on the employers. The Court also pointed out that the parties failed to present sufficient evidence regarding the post-employment medical examination requirement. Therefore, the Court reversed the CA's decision and reinstated the NLRC's ruling.

2. The burden of proof lies on the party asserting that the seafarer was repatriated for medical reasons, in this case, Lloyd. The employer has no burden to prove the reason for repatriation unless it is asserted by the seafarer. In this case, Lloyd failed to present substantial evidence to prove his allegation that he was medically repatriated.

3. Lloyd did not present substantial evidence to prove that he reported to the company-designated physician after his repatriation. The Court agreed with the NLRC's finding that Lloyd did not report to the company-designated physician.

4. Lloyd is not entitled to total and permanent disability benefits under the POEA-SEC because he did not suffer an illness or injury during the term of his contract. His illness manifested or was discovered after the term of his contract, thus, a different provision of the POEA-SEC applies.

5. Section 32-A of the POEA-SEC applies in this case as Lloyd's illness manifested or was discovered after the term of his contract.

6. Lloyd Espinosa is not entitled to total and permanent disability benefits.

7. Lloyd failed to prove a reasonable link between his illnesses and the nature of his work.

PRINCIPLES:

• The burden of proof rests upon the party who asserts a fact, not upon he who denies it.

• The rule on burden of proof in illegal dismissal cases cannot be unduly applied in proving whether a seafarer was repatriated for medical reasons.

• The employer has no burden to prove the reason for repatriation unless it is asserted by the seafarer.

• The seafarer has the duty to establish their affirmative allegation that they submitted themselves to post-medical examination after repatriation.

• Compliance with the reportorial requirement applies to claims for sickness allowance and disability benefits.

• In resolving claims for disability benefits, the POEA-SEC should be integrated with every agreement between a seafarer and his employer.

• Section 20-A of the POEA-SEC applies if the seafarer suffers from an illness or injury during the term of his contract, while Section 32-A applies if the illness manifests or is discovered after the contract.

• For a work-related illness listed under Section 32-A of the POEA-SEC, the seafarer must show compliance with the conditions stated in Section 32-A to be entitled to disability benefits.

• For an illness not listed as an occupational disease in Section 32-A of the POEA-SEC, the seafarer may still claim provided there is a reasonable linkage between the disease and the seafarer's work.

• Substantial evidence is required to establish entitlement to benefits provided by law. The test of proof in compensation proceedings is probability, and conclusions must be based on real evidence and not just inferences and speculations.

• In order to be entitled to disability benefits, the seafarer must prove a reasonable link between his illnesses and the nature of his work.

• The relationship of the risk and the diseases must be established to prove the reasonable link between the illnesses and the nature of work.

• The award of compensation and disability benefits cannot be based on speculations, presumptions, and conjectures.

• Financial assistance may be granted to separated employees for humanitarian reasons and compassionate justice.