The more recent jurisprudences are leaning towards our favor such
as the case of MADRIDEJOS vs. NYK-FIL SHIP MANAGEMENT, INC.,
(G.R. No.204262, 07 June 2017) wherein the court held as follows:
"A seafarer only needs to pass the mandatory
[Pre-Employment Medical Examination] in order to be deployed on duty at sea." A Pre-Employment Medical Examination cannot be relied upon to reflect a "seafarer's true state of health" since it is not exploratory and may just disclose enough for employers to decide whether a "seafarer is fit for overseas employment." Due to the nature of a Pre- Employment Medical Examination, it is possible that Madridejos' sebaceous cyst was not detected prior to his employment.