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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.

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