Understanding Disability Benefits for Seafarers: Insights from a Supreme Court Ruling on Financial Assistance

The Supreme Court’s 2020 ruling in Heirs of Amadeo Alex G. Pajares v. North Sea Marine Services Corporation (G.R. No. 244437) offers important guidance for seafarers and their families navigating disability claims. The case clarifies the difference between disability benefits and financial assistance, and underscores a critical procedural rule: a party who does not appeal cannot seek affirmative relief.

The Case: A Seafarer’s Fight for Benefits

Amadeo Pajares worked as a Suite Attendant on a cruise ship for North Sea Marine Services Corporation. His duties involved housekeeping and cleaning cabins, which exposed him daily to strong chemical cleaning agents. During his contract, he suffered severe nose bleeding and was eventually diagnosed with Multiple Myeloma, a type of blood cancer. He was repatriated to the Philippines and referred to the company-designated physician.

The company-designated physician declared the illness not work-related. Pajares later consulted an independent physician who declared him unfit for sea service. When the company refused to provide copies of his medical records and did not act on his request for a third medical opinion, the matter went to voluntary arbitration.

The Procedural Hurdle: No Appeal, No Relief

The Panel of Voluntary Arbitrators dismissed the claim for total and permanent disability benefits, finding that Pajares failed to present substantial evidence to rebut the company physician’s findings. However, for humanitarian reasons, the Panel awarded financial assistance of US$20,000.

It was the company that appealed to the Court of Appeals (CA), questioning the financial assistance award. Pajares did not appeal the denial of his disability claim. Instead, he raised his objections in his Comment to the company’s appeal.

The Supreme Court ruled that a party who does not appeal cannot seek affirmative relief. As the Court explained, due process and fair play dictate that a non-appellant may not be granted additional awards or benefits, nor may he or she assail or ask for modification of a judgment that was not appealed. Because Pajares did not appeal the denial of his disability benefits claim, the Court could not entertain that issue.

Disability Benefits vs. Financial Assistance

The case highlights an important distinction. Disability benefits are contractual or statutory entitlements that must be proven with substantial evidence. In this case, the company-designated physician’s findings—that Multiple Myeloma was not work-related—were upheld because Pajares failed to present convincing proof to rebut them. The independent physician’s report was submitted only after Pajares’s death, without justification for the delay.

Financial assistance, on the other hand, is a discretionary award. The Court has, in several instances, granted financial assistance to employees for humanitarian considerations, applying the principle of social and compassionate justice for the working class. The award is subject to the sound discretion of the courts.

The Final Award

The CA reduced the financial assistance from US$20,000 to US$8,500, based on the amount the company had offered during a conference. The Supreme Court upheld this amount, noting that Pajares had rendered several years of service, had no derogatory records, and his employment ended not due to any infraction but because of a debilitating illness.

Practical Takeaways

• File a timely appeal. A seafarer who disagrees with an adverse ruling on disability benefits must appeal that ruling. Raising objections in a Comment to the other party’s appeal is not enough.
• Gather evidence early. Substantial evidence is required to rebut a company-designated physician’s findings. Obtain and preserve medical reports, and submit them promptly.
• Know the difference. Disability benefits require proof of work-relatedness and disability. Financial assistance is a discretionary, humanitarian award that courts may grant even without such proof.
• Request medical records. Seafarers have the right to request copies of their medical assessments. Timely requests and documentation of refusals can strengthen a case.
• Consider the company’s offer. An employer’s offer of financial assistance during proceedings may influence the final amount awarded by the courts.

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