Ernesto Arriesgado was working as an oiler aboard a cargo vessel. Like many seafarers, life on board was not limited to work. During their free time, crew members played basketball to relax and keep themselves physically active.

One day, while playing in a basketball game between the vessel’s deck and engine teams, Ernesto was accidentally elbowed in the left side of his chest. The impact caused severe pain and difficulty breathing.

He immediately reported the incident to the duty officer. At first, he was given pain relievers, warm compresses, and a pain patch. But when the pain persisted, he was eventually brought to a hospital in Yokohama, Japan. Doctors diagnosed him with injuries to his ribs and chest and declared him unfit for duty, recommending that he be repatriated for further treatment.

He was flown back to the Philippines. After his arrival, the company-designated physician treated him conservatively with medication. Months passed. Although Ernesto continued attending his follow-up consultations, his pain persisted.

Eventually, the company physician told him to speak with the agency regarding his future treatment. No final disability assessment was issued. Feeling that his treatment had effectively ended, Ernesto consulted his own physician, who declared him permanently unfit for sea duty. He then sought disability benefits.

The employer refused. According to the company, Ernesto was injured while playing basketball—a purely recreational activity unrelated to his duties as an oiler. Therefore, they argued, the injury was not work-related and was not compensable. The dispute reached the Supreme Court. Was the injury work-related even though it happened during a basketball game?

Yes, it was. The Court explained that seafarers occupy a unique position.

Unlike ordinary employees who go home after work, seafarers are required to live on board their employer’s vessel throughout the duration of their contracts. Because of this, the Court applied what is known as the Bunkhouse Rule. Under this doctrine, injuries sustained while an employee is required to live on the employer’s premises may still be considered work-related, even if they occur outside regular working hours.

The Court also applied the Personal Comfort Doctrine, which recognizes that activities reasonably necessary for an employee’s health, comfort, or well-being remain incidental to employment because healthier and better-rested employees ultimately benefit the employer.

The Court noted that the employer itself admitted that the basketball game was intended as a recreational activity for the crew. Such activities promote physical and mental well-being and ultimately improve the crew’s performance on board.

Accordingly, Ernesto’s injury arose in the course of his employment. The Supreme Court also rejected the employer’s claim that Ernesto had abandoned his medical treatment. The records showed that Ernesto consistently reported to the company-designated physician for several months. It was the physician who eventually instructed him to discuss his future treatment with the agency instead of continuing medical management. Under those circumstances, Ernesto was justified in believing that his treatment had already been discontinued.

The Court likewise found another serious problem. The company-designated physician never issued a final, complete, and definite medical assessment within the period required by the POEA Standard Employment Contract. Instead, he repeatedly suggested that Ernesto was merely exaggerating his condition and seeking retirement benefits, without making a definitive finding regarding his fitness to return to sea duty.

Worse, despite Ernesto’s repeated requests, the company failed to furnish him copies of his medical reports, depriving him of information necessary to protect his rights. Because no valid and timely final medical assessment was issued, Ernesto’s disability became total and permanent by operation of law.

The Court awarded him US$60,000 in total and permanent disability benefits under the POEA Standard Employment Contract, differential sickness allowance, and ₱50,000 in nominal damages for the employer’s violation of his due process rights and its failure to provide him with his medical records.

However, the Court denied his claims for moral damages, exemplary damages, and attorney’s fees because the employer’s refusal to pay disability benefits was based on a genuine—although mistaken—belief that the injury was not compensable. Accordingly, the Supreme Court held that a seafarer injured while engaging in an employer-sanctioned recreational activity on board the vessel may still be entitled to disability benefits.

The Court emphasized that, because seafarers are required to live aboard their employer’s vessel, injuries sustained while attending to their personal comfort or participating in reasonable recreational activities may arise out of and in the course of employment. Where the company-designated physician also fails to issue and furnish a valid, timely, and final medical assessment, the seafarer’s disability becomes total and permanent by operation of law.

Arriesagado v. Multinational Maritime, Inc. G.R. No. 275424, April 29, 2026.