Varying physicians’ findings on seafarer’s disability

Petitioner Leonis Navigation Company, Inc. (LNCI), for and on behalf of its foreign principal co-petitioner World Marine Panama S. A. (World Marine), hired respondent Eduardo C. Obrero as a messman onboard M/V Brilliant Arc on Oct. 3, 2003. He was deployed on Feb. 20, 2004. Sometime in October 2004, Obrero’s crewmates observed him acting strangely. The Master Report noted that Obrero’s normal manner changed and that he was unable to sleep well. It added that Obrero could no longer perform his daily tasks and showed signs “of abnormality towards his daily gestures especially to the crew and other things.”

Shortly after his arrival in the Philippines, he was examined by Dr. Nicomedes Cruz, the company- designated physician. Dr. Cruz initially diagnosed him with major depression and referred him to a psychiatrist. His diagnosis was updated to “schizophreniform disorder”. In his certification, Dr. Cruz stated that “schizophreniform disorder appears to be related to abnormalities in the structure and chemistry of the brain, and appears to have strong genetic links” and “categorically speaking schizophreniform disorder is not work-related.”

Obrero sought the opinion of a psychiatrist, Dr. Pacita Ramos-Salceda, who diagnosed him as suffering from “psychotic disorder, not otherwise specified.” Dr. Salceda noted that although Obrero was initially able to cope with the rigors and stress of his occupation, his coping abilities were eventually taxed “as he was continuously exposed to the adverse situation of repeatedly being at sea for prolonged periods of time.” Additionally, he was not able to handle the stress of being demoted from seaman to messman as a result of the discovery of his color blindness.

In connection with Obrero’s claim for total disability bene- fits, which of the two doctors’ findings should be given more credence?

Ruling: Those of Dr. Pacita Ramos-Salceda.

Here, the Supreme Court agreed with the Court of Appeals (CA) and National Labor Relations Commission (NLRC) that Obrero has successfully proved that his illness was work-related. Taken together, Dr. Salceda’s diagnosis and Obrero’s previous unremarkable stints as a seaman reasonably support the conclusion that his work environment increased his risk of developing or triggering schizophrenia.

As detailed in Dr. Salceda’s diagnosis, Obrero’s demotion to messman—which is inherently work-related and was conveniently ignored by LNCI in its pleadings—appears to be the event that precipitated his mental disorder. Prior to this, he was able to accomplish his tasks without any issue as an ordinary seaman (OS) from Jan. 20, 2000 to Feb. 3, 2001, and as an able seaman (AB) from Aug. 12, 2001 to June 27, 2002 and May 14, 2003 to June 11, 2003.

Applying the standard of substantial evidence, i.e., that amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion, we find Dr. Salceda’s explanation—that Obrero’s prolonged stint at sea eventually taxed his coping abilities which rendered him incapable of handling the stress of being demoted—to be reasonable and highly probable.

We stress that the reason behind our rulings that favor the findings of company-designated physicians is not because they are infallible; rather, it is because of the assumption that they have “closely monitored and actually treated the seafarer” and are therefore in a better position to form an accurate diagnosis. ( Jardeleza, J., SC 3rd Division, Leonis Navigation Co., Inc., et. al. vs. Eduardo C. Obrero, et. al., G.R. No. 192754, Sept. 7, 2016).