Seafarer Disability Claims: When Injury During a Basketball Game Counts as Work-Related

Seafarers spend months confined to a vessel, and injuries during off-duty recreation are common. A recent Supreme Court decision clarifies when such injuries are compensable — and when a company doctor's assessment does not settle the matter. In Arriesgado v. Multinational Maritime, Inc., G.R. No. 275424 (April 29, 2026), the Court held that an injury sustained during a basketball game on board a vessel is work-related, and that the seafarer's claim for total and permanent disability benefits was justified.

The facts of the case

Ernesto Arriesgado was hired as an oiler in October 2020. On January 10, 2021, while playing in a basketball game between the vessel's deck and engine teams, he was elbowed in the left abdomen. He felt severe pain and shortness of breath.

He was medically repatriated on January 25, 2021, after a Japanese hospital diagnosed a fracture of the left costal cartilage, contusion, and an incomplete fracture of the left rib. The company-designated physician later reported only a contusion, advised conservative treatment, and said Arriesgado could return to work in two to three weeks. The doctor also stated that the injury was not work-related because it was not among the listed occupational diseases under the 2010 POEA-SEC.

Over the following months, Arriesgado continued to report pain. On April 23, 2021, the company doctor advised him to discuss his future treatment with the agency. Arriesgado then consulted an independent physician, who declared him permanently unfit for sea duties. When the parties could not settle, he filed a complaint for total and permanent disability benefits.

The rulings below

The labor arbiter dismissed the complaint, finding the injury was sustained during rest and recreation and was therefore not work-related. The National Labor Relations Commission reversed this, holding that the basketball game was a company-organized activity for the crew's well-being, and that the company doctor's termination of treatment without a final assessment made the disability total and permanent by operation of law. The Court of Appeals then reinstated the labor arbiter's dismissal, finding grave abuse of discretion on the NLRC's part.

The Supreme Court's ruling

The Supreme Court ruled in favor of the seafarer. It held that the Court of Appeals erred in finding grave abuse of discretion on the NLRC's part, because the NLRC's conclusions were supported by substantial evidence.

Two principles governed the work-relatedness of the injury: the Bunkhouse Rule and the Personal Comfort Doctrine. Under the Bunkhouse Rule, employees required by the nature of their work to stay on the employer's premises are considered to be performing services incidental to their employment while there. Seafarers, by the nature of their work, must live on board the vessel for the entire contract period.

The Personal Comfort Doctrine provides that acts relating to an employee's personal comfort — including breaks that help them perform better — do not take them out of the course of employment. Recreational activities expressly or impliedly sanctioned by the employer, which improve the crew's well-being and ultimately benefit the employer, fall within this doctrine.

The Court also cited Board Resolution No. 24-12-40 of the Employees' Compensation Commission, which declared compensable injuries sustained by seafarers during free time or beyond regular working hours while on board a vessel.

To deny compensation, the employer must prove that the injury was directly attributable to the seafarer and resulted from a willful or criminal act or intentional breach of duty under Section 20(D) of the 2010 POEA-SEC. Here, the employer failed to show any such act. The Court also rejected the argument that a prior ruling denying a claim by a casino dealer injured in the ship's gym applied, noting that the seafarer in that case gave conflicting accounts and lacked diagnostic support for his claim.

Why the company doctor's assessment was not decisive

The Court noted that the company-designated physician discontinued treatment and advised the seafarer to discuss his future treatment with the agency, without issuing a final assessment. Under the rules, when the company doctor fails to issue a final assessment within the prescribed period, the seafarer's disability may be considered total and permanent by operation of law.

The Court also addressed the three-day reportorial requirement under Section 20(A)(3) of the 2010 POEA-SEC, which requires a seafarer to submit to post-employment medical examination within three working days from repatriation. This requirement admits exceptions, including when the employer refuses or fails to submit the seafarer for examination. The seafarer's claim was not barred.

Practical takeaways

• Injuries during employer-sanctioned recreation on board a vessel — including basketball games — may be considered work-related under the Bunkhouse Rule and the Personal Comfort Doctrine.
• The employer bears the burden of proving that the injury resulted from the seafarer's willful or criminal act or intentional breach of duty to deny compensation.
• A company-designated physician's assessment is not automatically conclusive; failure to issue a final assessment within the prescribed period can render the disability total and permanent by operation of law.
• Seafarers should document their injury, comply with medical examinations, and secure copies of all medical records.
• The three-day reportorial requirement is not absolute and admits recognized exceptions.

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