Labor Law

ANTONIO B. MANANSALA v. MARLOW NAVIGATION PHILS.
G.R. No. 208314, August 23, 2017
LEONEN, J.:
FACTS:
On April 8, 2010, Manansala’s services were engaged by Marlow Navigation Phils., Inc., for and
on behalf of its principal, Marlow Navigation Co. Ltd./Cyprus, for him to serve as a "fitter" on
board the vessel M/V Seaboxer.
Before boarding the vessel, Manasala underwent a Pre-Employment Medical Examination and
was required to disclose information regarding all existing and prior medical conditions.
Manansala's examination certificate indicates that he denied having hypertension and diabetes,
specifically answering "NO" when asked about hypertension and diabetes mellitus. Following
his examination, Manansala was declared fit for sea duty and was deployed.
While on board the M/V Seaboxer, Manansala suffered a stroke. He was, then, admitted to the
ADK Hospital in the Maldives where a brain CT scan conducted on him showed that he was
suffering from an “acute infarct at the left MCA territory." Because of this, Manansala was
repatriated.
Although Manansala was confined at the De Los Santos Medical Center, he "repeatedly denied
that he had any past history of diabetes and hypertension." Thereafter, Manansala was issued an
interim Grade 10 disability rating.
Manansala filed a Complaint against the respondents for total and permanent disability benefits,
as well as damages and attorney's fees. Two (2) months after he filed his Complaint, Manansala's
own doctor, issued a medical opinion stating that Manansala must be considered permanently
disabled.
ISSUE:
Is Antonio B. Manansala is entitled to total and permanent disability benefits occasioned by

work-related illnesses?
RULING:
No.
Manansala's assertion is an admission that he fully knew of his conditions at the moment he was
examined, rendering it pointless for this Court to consider whether he was merely confused at the
time of his examination. Additionally, his assertion burdens him with the task of proving his
claims. As he was duty-bound to truthfully answer questions during his examination, Manansala
must show that despite his knowledge, he did not willfully or deceptively withhold information.
Likewise, his imputation of the examining physician's liability despite the examination
certificate's indication that his responses were duly recorded is an affirmative defense or an
alternative version of events that becomes his burden to prove.
Manansala failed to discharge his burden. On the contrary, the confluence of circumstances
belies his claims.
Manansala adequately understood the significance of the declarations attributed to him in his
examination certificate. Manansala's engagement aboard the MIV Seaboxer was not his first stint
as a seafarer. He had been a seafarer since 1994, although he worked for respondents, on and off,
only since 2007. His prolonged seafaring experience must have familiarized him with the
conduct of PEMEs and the need for him to give truthful answers. He explicitly declared, too, that
he was "aware of the contents of Section 20.E [on misrepresentation] in the POEA [Standard
Employment Contract]." Certainly, his awareness of Section 20(E) must have impressed upon
him not only the potential complications of what he claims to be a false declaration foisted on
him by the examining physician but also the urgency of rectifying that error. Instead, he
remained silent and did nothing. Manansala's concession by omission militates against him.
This Court has nothing to rely on but Manansala's bare recollection. This does not satisfy, He
should have actively endeavored to demonstrate that the false declarations in his examination
certificate were anomalous, stray errors. As a seafarer since 1994, he must have completed
several other medical examinations. His good faith could have been substantiated by prior acts in
analogous situations. He could have presented copies of the certificates for his previous medical
examinations, but he did not These would have shown that while the responses he otiered about
his conditions in prior instances had been properly recorded, the examining physician during his
March 23, 2010 examination failed to render an accurate account.

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ANTONIO B. MANANSALA v. MARLOW NAVIGATION PHILS.

G.R. No. 208314, August 23, 2017

Is Antonio B. Manansala is entitled to total and permanent disability benefits occasioned by

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