Eduardo v. Leonidas

Summary

Long-serving seafarer Eduardo Leonidas worked for respondents from 2000-2010, developing chronic atrial fibrillation in 2006 requiring anti-coagulant medication. Despite continued employment through 2009 with knowledge of his condition, respondents prevented him from boarding in 2010 citing company guidelines against anti-coagulant use. The Supreme Court denied his disability benefits claim for failure to prove work-relatedness under POEA-SEC requirements but found respondents liable for breach of perfected employment contract. The Court distinguished between contract perfection (requiring only consent, object, and cause) and commencement of employment relationship (requiring POEA approval and deployment). The decision awarded actual damages equivalent to six months' salary plus attorney's fees, establishing important precedent on maritime employment contract obligations and the distinction between disability compensation and contract breach remedies in seafarer cases.