Seafarer Basketball Injury Held Work-Related Under Bunkhouse Rule

The Supreme Court recently ruled that a seafarer who sustained an injury while playing basketball on board a vessel is entitled to total and permanent disability benefits. The case clarifies when recreational activities during free time on a ship are considered work-related, a question that frequently arises in maritime labor disputes.

In Arriesgado v. Multinational Maritime, Inc. (G.R. No. 275424, April 29, 2026), the Court reversed the Court of Appeals and reinstated the NLRC's award of USD 104,866.00 in disability benefits plus attorney's fees to a seafarer injured during a basketball game between the vessel's deck and engine teams.

The Facts of the Case

Ernesto Arriesgado was hired as an oiler on board MV "Kariyushi Leader" for a nine-month contract. In January 2021, he joined a basketball game between the vessel's deck and engine teams. During the game, his left abdomen was elbowed, causing immense pain and shortness of breath.

He was medically repatriated after examinations in Japan revealed a fracture of the left costal cartilage, contusion on the left abdominal region, and an incomplete fracture on the left rib. The company-designated physician later claimed there was no rib fracture and treated him conservatively.

After several months of treatment with persistent pain, the company-designated physician advised Arriesgado to discuss his future treatment with the agency. Arriesgado then consulted an independent physician who declared him permanently unfit for further sea duties.

The Legal Issue

The central question was whether an injury sustained during a basketball game on board a vessel—an activity outside the seafarer's actual duties—is work-related and compensable under the 2010 POEA-SEC.

The company argued that playing basketball was purely for leisure and not incidental to the seafarer's duties as an oiler, citing Guerrero v. Philippine Transmarine Carriers, Inc., where the Court denied a claim involving a casino dealer injured while working out in the ship's gym.

The Court's Ruling

The Supreme Court ruled in favor of the seafarer, applying two established doctrines:

The Bunkhouse Rule. Seafarers are required to live on the vessel for the duration of their employment contract. Under this rule, injuries sustained on the employer's premises are considered in the course of employment regardless of when they occurred. The Court noted that the employer's obligation to be on the premises creates the risk of injury.

The Personal Comfort Doctrine. Acts relating to an employee's personal comfort—including recreational activities sanctioned by the employer—do not break the course of employment. These activities benefit the employer indirectly by producing better work from rested and satisfied employees.

The Court distinguished Guerrero, noting that the denial there rested on additional factors: the seafarer gave conflicting accounts of his injury, raised his claim late, and his independent physician's declaration lacked supporting diagnostic tests.

Burden of Proof on the Employer

Under Section 20(D) of the 2010 POEA-SEC, no compensation is payable if the injury results from the seafarer's willful or criminal act or intentional breach of duties. However, the employer bears the burden of proving that the injury is directly attributable to the seafarer's misconduct.

In this case, the company failed to prove that Arriesgado committed any crime or willful breach of duty. The company even admitted that the basketball game was intended as a recreational activity for the crew's well-being.

The Three-Day Reportorial Requirement

The Court also addressed the requirement under Section 20(A)(3) of the 2010 POEA-SEC that a seafarer submit to post-employment medical examination within three working days from repatriation. This rule admits exceptions, including when the employer refuses or fails to properly conduct the examination.

Here, the company-designated physician's failure to issue a final assessment despite months of treatment supported the seafarer's claim that his disability became total and permanent by operation of law.

Practical Takeaways

• Recreational injuries on board are generally compensable. Seafarers who sustain injuries during sanctioned recreational activities on the vessel are entitled to disability benefits under the Bunkhouse Rule and Personal Comfort Doctrine.
• Employers bear a heavy burden. To deny compensation, the employer must prove the injury resulted from the seafarer's willful act, criminal conduct, or intentional breach of duties.
• The 2010 POEA-SEC governs. Work-relatedness is determined under the POEA-SEC, not the specific terms of the collective bargaining agreement regarding recreational facilities.
• Timely medical assessment matters. A company-designated physician who fails to issue a final assessment within the prescribed period risks the disability being deemed total and permanent by operation of law.
• Guerrero is not a blanket rule. Each case turns on its specific facts, including whether the employer sanctioned the activity and whether the seafarer's evidence is credible and supported by diagnostic tests.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.