Case Digest (G.R. No. 194758)
Facts:
Ruben D. Andrada v. Agemar Manning Agency, Inc., and/or Sonnet Shipping Ltd./Malta, G.R. No. 194758, October 24, 2012, Supreme Court Third Division, Mendoza, J., writing for the Court. Petitioner Ruben D. Andrada was employed by respondent Agemar Manning Agency, Inc. for and on behalf of its foreign principal Sonnet Shipping Ltd./Malta as chief cook steward under a contract beginning June 23, 2003 (boarded June 24, 2003) with a basic wage in US dollars; he had completed prior contracts with the respondents dating back to 1994.While at sea in April 2004 Andrada experienced abdominal pain that recurred later; on October 10, 2004 he was diagnosed in Texas with an umbilical hernia and advised to undergo surgery. He was repatriated December 8, 2004 for treatment. After arrival he was referred to YGEIA Medical Clinic; Dr. Roberto De Leon recommended surgery for umbilical hernia and gallstones (December 14, 2004). On January 25, 2005 Andrada underwent umbilical herniorrhaphy and laparoscopic cholecystectomy at the Philippine General Hospital under Dr. Jose Faylona and was confined January 25–29, 2005.
On February 8, 2005 Dr. Efren Vicaldo issued a medical certificate diagnosing, inter alia, hypertension and assessing an Impediment Grade VIII (33.59%), opining that the illness was work-aggravated/related and that Andrada was unfit to resume seafaring duties. Conversely, Dr. Faylona (March 14, 2005) and Dr. Maria Cristina L. Ramos (YGEIA, March 22, 2005) later certified Andrada as fit to work. On April 21, 2005 Andrada executed a Deed of Release, Waiver and Quitclaim acknowledging receipt of US$3,501.53.
Andrada demanded disability and sickness benefits under the POEA Standard Employment Contract (POEA-SEC); respondents refused. He filed a complaint May 26, 2005 for disability benefits, sickness allowance, medical expense reimbursement, damages and attorney’s fees. The Labor Arbiter (LA) Ramon Valentin C. Reyes, in a January 9, 2007 decision, awarded disability benefits (US$32,419.20), concluding Andrada suffered permanent total disability and discounting the company physicians’ certifications as biased. The National Labor Relations Commission (NLRC) reversed the LA, finding no legal/factual basis for disability benefits given the company-designated physician’s certificate, the Deed of Release, and Andrada’s alleged non-disclosure of a pre-existing hernia; the NLRC set aside the LA decision.
Petitioner sought certiorari relief from the Court of Appeals (CA) alleging grave abuse of discretion by the NL...(Subscriber-Only)
Issues:
- Did the Court of Appeals err as a matter of law in its interpretation and application of Section 20(B), paragraph 3 of the POEA Standard Employment Contract regarding the authority of the company-designated physician?
- Did the Court of Appeals err in applying the correct law and jurisprudence on claims for full disability benefits and attorney’s fees?
- Did the Court of Appeals err in upholding the Deed of Release, Waiver and Quitclaim as a bar to ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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