Lacson vs. RCCL Crew Management Inc. (2025)

Case Title: Lacson vs. RCCL Crew Management Inc., Royal Caribbean Cruises Ltd., And Gerardo Antonio Borromeo
Citation: G.R. No. 270817
Date: January 27, 2025
Author: Hernando, J.

Parties:

• Petitioner: Charlonne Keith Lacson
• Respondents: RCCL Crew Management Inc., Royal Caribbean Cruises Ltd., and Gerardo Antonio Borromeo

Facts:

• Charlonne Keith Lacson was hired by RCCL Crew Management Inc. on behalf of Royal Caribbean Cruises Ltd. as AZ Commis 2, with duties including food preparation and kitchen sanitation.
• Lacson was exposed to cleaning materials, sanitizers, bleaches, acids, degreasers, and detergents, and after a few months, he experienced skin itching, which progressed into painful skin rashes and blisters.
• He was medically repatriated on August 20, 2018, and diagnosed with Contact Dermatitis with Secondary Bacterial Infection by the company-designated physician, Shiphealth, Inc.
• Despite ongoing post-employment medical evaluations and treatment, RCCL asked him to report for redeployment even with visible skin rashes.
• Lacson consulted a dermatologist at Seamen’s Hospital, who diagnosed him with Hand Dermatitis R/O Allergic Contact Dermatitis and declared him unfit for duty. He also consulted Dr. Miguel Maralit, who diagnosed him with Dyshidrotic Eczema and Nummular Eczema and declared him unfit to work in the kitchen.
• Lacson filed a complaint for permanent and total disability benefits, which was denied by the Labor Arbiter and the NLRC. The Court of Appeals affirmed the NLRC’s decision.

Ruling:

The Supreme Court partly granted the petition, finding that Lacson is entitled to permanent and total disability benefits. The Court of Appeals’ decision was reversed and set aside.

Findings:

• [Presumption of work-related illness or injury in favor of seafarers:] “[U]nder Section 20, par. (A) of the POEA-SEC, the employer shall be liable for disability benefits only when (1) the seafarer suffers a work-related injury or illness, and (2) the illness or injury existed during the term of the seafarer’s employment contract. Moreover, those illnesses not mentioned under Section 32 of the POEA-SEC are disputably presumed as work-related.”
• “Citing Reyes v. Jebsens Maritime, Inc.: ‘The law clearly laid down a legal presumption of work-related illness or injury in favor of seafarers. This legal presumption was borne by the fact that the said list cannot account for all known and unknown illnesses/diseases that may be associated with, caused or aggravated by such working conditions, and that the presumption is made in the law to signify that the non-inclusion in the list of occupational diseases does not translate to an absolute exclusion from disability benefits. Thus, the burden is on the employer to disprove the work-relatedness, failing which, the disputable presumption that a particular injury or illness that results in disability is work-related stands.’”
• “However, this disputable presumption does not equate to the automatic grant of disability benefits claim. The seafarer must justify one’s entitlement to disability benefits by providing substantial evidence of the work-relatedness of his/her illness or disease.[60] Otherwise stated, petitioner must establish the reasonable causal connection between his nummular eczema and the work for which he was contracted. On the other hand, respondents carry the burden of disproving the work-relatedness of petitioner’s nummular eczema.”
• Work-Relatedness of the Illness: “Respondents do not dispute that petitioner’s work constantly exposed him to cleaning agents and chemicals. They only harp on the fact that petitioner had previously declared in his Medical Certificate For Sea Service that he has/had prior allergies.”
• “”Thus, while petitioner indicated “Yes” to allergies/anaphylaxis to environment, chemicals, food or drugs, it was also clearly indicated therein that it specifically pertained to latex and nickel. This disclosure does not indicate that petitioner was making a general admission of allergy to environment, chemicals, food, or drugs as a whole, but rather acknowledging those specific allergens only. Notably, the records do not show that petitioner had exposure to latex and nickel while performing his work as AZ Commis 2. Consequently, there is no basis to support respondents’ claim that petitioner’s illness was already pre-existing as declared in his Medical Certificate Fit for Sea Service. In any case, compensability of an illness does not depend on whether the injury or disease was pre-existing at the time of employment but rather on whether the injury or illness is work-related or had been aggravated by the seafarer’s working condition. In addition, if petitioner had already been afflicted with nummular eczema prior to employment, these rashes would have been visible during his pre-employment examination, and he would not have been cleared for duty or placed in charge of food preparation and kitchen sanitation. In fact, he would not have been employed at all if he had this condition prior to his employment.””
• “Respondents failed to offer any evidence to controvert the work­relatedness of petitioner’s nummular eczema. To recall, petitioner’s work as AZ Commis 2 entailed exposure to cleaning materials such as sanitizers, bleaches, acids, degreasers, and detergents. His direct exposure to these chemicals, stress, and climate changes, coupled with Dr. Maralit’s certification that petitioner is suffering from dyshidrotic eczema and nummular eczema, confirm the existence of a reasonable connection between the nature of his work and his eczema. Worth noting too is Dr. Maralit’s declaration that petitioner is unfit to work in the kitchen and recommended his transfer to another department. Thus, at the time of petitioner’s examination by his own physicians of choice, his nummular eczema had not yet been resolved.”
• “Surely, in its Final Report, Shiphealth failed to provide any declaration as to petitioner’s capacity to return to work, nor any categorical and final degree of AZ Commis 2/Azmara QuestRespondents also failed to dispute petitioner’s claim that the latter only saw the Final Report for the first time in their position paper. Thus, We find merit in petitioner’s claim that the Final Report was issued beyond the 120/240-day period for respondents’ failure to furnish him a copy thereof within the said periods.”
• “Shiphealth failed to issue the final and definite medical assessment required by law. Records are bereft of any proof that respondents informed petitioner of Shiphealth’s final and definite assessment within the prescribed periods. In fact, the Final Report was addressed to the Crew Medical Case Manager of Royal Carribean Cruises, Ltd., rather than petitioner. Neither is there any allegation or proof that a copy of the said report was furnished to petitioner.”
• “The Court also observes that the Crew Fit for Duty Notice dated January 24, 2019 was not issued by Shiphealth and therefore, cannot be considered as the declaration of petitioner’s capacity to work within the purview of the required final and definite medical assessment. In addition, the failure of the report to indicate the name of the alleged specialist who examined the seafarer renders it dubious. Thus, the CA erred in considering Shiphealth’s Final Report dated January 17, 2019 as valid, final, and definite.”
• “The lack of a conclusive and definite assessment from respondents’ company-designated physician left petitioner nothing to properly contest.  In other words, since there is no valid, final, and definite assessment by Shiphealth, there is no need for petitioner to initiate the referral to a third doctor for him to be entitled to permanent disability benefits. It was by operation of law that petitioner became permanently disabled.[80] As such, he is entitled to a disability pay of USD 60,000.00 or its peso equivalent at the time of payment.”

Disposition:

ACCORDINGLY, the petition is GRANTED. The Decision dated April 14, 2023 and the Resolution dated October 10, 2023 of the Court of Appeals in CA-G.R. SP No. 171761 are REVERSED and SET ASIDE. Respondents are jointly and severally liable to pay petitioner Charlonne Keith Lacson the amount of USD 60,000.00 or its equivalent amount in Philippine currency at the time of payment plus ten percent (10%) as attorney’s fees. Respondents are also ORDERED to PAY interest at the rate of six percent (6%) per annum from the date of finality of the Decision until full payment.

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NB: This case digest was generated with the assistance of Perplexity AI and then reviewed by a lawyer/J. Del Puerto.