Title
Abella vs. Abosta Shipmanagement Corp.
Case
G.R. No. 249358
Decision Date
Apr 28, 2021
Seafarer injured at work deemed permanently disabled by law due to employer's failure to provide timely medical assessment, receiving $60K in benefits.

Case Digest (G.R. No. 103501-03)
Expanded Legal Reasoning Model

Facts:

Employment and Deployment
Gregorio F. Abella worked as an oiler for Abosta Shipmanagement Corporation (Abosta) under a 10-month employment contract. He was deployed on March 20, 2016, on board M/V Sino Trader.

Injury and Initial Treatment
On June 23, 2016, Abella injured his lower back while carrying a sack of rice. He was treated with pain relievers and a waist protector. Due to persistent pain, he was treated in Singapore, where he was diagnosed with "Lumbar spondylosis with discopathy at L4L5L5S1." Later, he was treated in Brazil and eventually repatriated to the Philippines on August 6, 2016.

Medical Treatment in the Philippines
Upon his return, Abella reported to the company-designated physician on August 8, 2016, who diagnosed him with "Herniated Nucleus Pulpos L3-L4, Disc Protrusion L5-S1, and L-4 Radiculopathy" and recommended physical therapy. Abella claimed that his treatment was discontinued on February 16, 2017.

Disability Assessment and Dispute
On February 20, 2017, respondents informed Abella that he had a Grade 8 disability and offered US$16,795.00 as benefits. Abella requested further treatment or higher compensation, but it was denied. On April 25, 2017, Abella consulted an independent physician, Dr. Cesar H. Garcia, who declared him permanently unfit for sea duty.

Administrative Proceedings
Abella filed a complaint for total and permanent disability benefits, medical expenses, damages, and attorney's fees on May 24, 2017. The Labor Arbiter (LA) dismissed his claim, awarding only Grade 8 disability benefits. The National Labor Relations Commission (NLRC) and the Court of Appeals (CA) affirmed the LA's decision.

Issues:

  • Whether Abella is entitled to total and permanent disability benefits under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC).
  • Whether Abella is entitled to moral and exemplary damages and attorney's fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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