When a Shipboard Basketball Injury Is Work-Related: Arriesgado v. Multinational Maritime

The Supreme Court recently clarified when an injury sustained by a seafarer during leisure activities on board a vessel is compensable. In Arriesgado v. Multinational Maritime, Inc. (G.R. No. 275424, April 29, 2026), the Court held that a seafarer who was injured while playing basketball with crewmates during free time is entitled to total and permanent disability benefits. The ruling is a significant guide for seafarers and employers on the scope of work-relatedness under Philippine law.

Facts of the Case

Ernesto Arriesgado was hired as an oiler on board the MV "Kariyushi Leader" in October 2020. In January 2021, he joined a basketball game between the vessel's deck and engine teams. During the game, he was elbowed in the left abdomen, causing pain and shortness of breath. He was given pain relievers and monitored by the ship's officers.

After medical repatriation, the company-designated physician treated him for a contusion. Despite months of treatment, Arriesgado continued to experience pain. The physician eventually advised him to discuss future treatment with the agency. Arriesgado then consulted an independent physician, who declared him permanently unfit for sea duties.

The Legal Dispute

The labor arbiter dismissed Arriesgado's claim for disability benefits, ruling that his injury was not work-related because it happened during a basketball game, a period of rest and recreation. The NLRC reversed, granting his claim. The Court of Appeals, however, reinstated the labor arbiter's dismissal, applying the earlier case of Guerrero v. Philippine Transmarine Carriers, Inc., where a casino dealer's gym injury was held non-compensable.

The Supreme Court's Ruling

The Supreme Court ruled in favor of Arriesgado. The Court applied two established doctrines:

The Bunkhouse Rule. Seafarers are required to live on the vessel for the entire duration of their contract. Injuries sustained on the employer's premises, regardless of when they occur, are considered in the course of employment.

The Personal Comfort Doctrine. Acts that minister to an employee's personal comfort—like eating, resting, or engaging in sanctioned recreation—do not break the course of employment. Such activities help employees perform their jobs better, and employers benefit indirectly from rested and satisfied workers.

The Court distinguished Guerrero, noting that the seafarer there gave conflicting accounts of his injury and his disability claim was not supported by diagnostic tests. In contrast, Arriesgado consistently reported the basketball incident, and his injury was documented by both the company-designated physician and an independent doctor.

The Court also noted that the employer has the burden of proving that an injury resulted from a seafarer's willful or criminal act under Section 20(D) of the 2010 POEA-SEC. The employer failed to do so here.

Key Rules Established

1. Work-relatedness is presumed for injuries sustained on board during free time, subject to the exceptions in Section 20(D) of the 2010 POEA-SEC.
2. The Bunkhouse Rule applies because seafarers are required to live on the vessel for the duration of their contract.
3. Recreational activities sanctioned by the employer—even informally—fall within the Personal Comfort Doctrine.
4. The employer bears the burden of proving that an injury resulted from a seafarer's willful or criminal act.

Practical Takeaways

• Seafarers injured during sanctioned recreational activities on board should promptly report the incident and document their treatment.
• The three-day post-repatriation medical examination requirement admits exceptions, including when the seafarer is incapacitated or the employer fails to arrange the examination.
• Employers cannot deny disability claims simply because an injury occurred during leisure time; they must prove willful or criminal conduct by the seafarer.
• The distinction from Guerrero shows that each case depends on its facts—consistent reporting and medical documentation are critical.

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