Facts:

In this case, Wilfredo Y. Antiquina (Petitioner) filed a Petition for Review on Certiorari against Magsaysay Maritime Corporation and Masterbulk, Pte., Ltd. (Respondents). The proceedings initiated in this case arose from a work-related accident that occurred on September 22, 2000, during Antiquina's employment as a Third Engineer on the vessel M/T Star Langanger, which was owned and operated by Masterbulk and manned by Magsaysay Maritime Corporation. The nature of his job took a dramatic turn when he suffered a fracture of his lower left arm after a part fell on him during routine maintenance. Following the incident, he received first aid and was then taken to a hospital in Romania, where he was diagnosed and treated. He was repatriated on October 3, 2000, and subsequently examined by Dr. Robert Lim in the Philippines, who confirmed his injury and advised physical therapy.

Despite undergoing therapy, Antiquina experienced unhealed results, prompting further medical evaluati

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Facts:

Employment and Contractual Background

• In February 2000, petitioner Wilfredo Y. Antiquina was hired through respondent Magsaysay Maritime Corporation (MMC) as Third Engineer on the vessel M/T Star Langanger, which was owned and operated by respondent Masterbulk Pte., Ltd.
• His employment contract, conforming to the standard POEA contract, specified a nine-month engagement at a salary of US$936.00 per month.
• Petitioner’s engagement commenced on March 1, 2000.

Work-Related Injury and Medical Treatment

• On September 22, 2000, while onboard during routine maintenance of the vessel’s H.F.O Purifier #1, petitioner sustained a fracture on his lower left arm when a part fell on him.
• Initial treatment was provided onboard; subsequently, petitioner was taken to a hospital in Constanza, Romania, where he was diagnosed with "fractura 1/3 proximala cubitus stg." and his arm was put in a cast.
• After being signed off at Port Said, Egypt on October 1, 2000, he was repatriated to the Philippines, arriving on October 3, 2000.
• Upon reporting to MMC on October 4, 2000, petitioner underwent further medical evaluation at Metropolitan Hospital where an undisplaced fracture of the left ulna was confirmed by Dr. Robert Lim.
• Despite months of physical therapy post cast removal, petitioner experienced persistent difficulty in straightening his arm.
• A company-designated physician, Dr. Tiong Sam Lim, advised a bone grafting procedure entailing the installation of a metal piece, which would only be removed after one and a half years; petitioner refused the recommended operation allegedly out of fear.

Claims and Procedural History

• After notifying respondents of his decision to forego the operation, petitioner filed a complaint for permanent disability benefits, sickness allowance, damages, and attorney’s fees.
• In his position paper before the Labor Arbiter, petitioner asserted entitlement to:
• Sickness allowance for 120 days equivalent to his basic wage (as stipulated in Section 20 of the POEA Standard Employment Contract).
• Permanent medical unfitness benefits based on a claimed higher benefit under Section 20.1.5 of a Collective Bargaining Agreement (CBA) with AMOSUP.
• Damages and attorney’s fees due to alleged negligence and delayed payment by respondents.
• The Labor Arbiter ruled in petitioner’s favor on September 27, 2002 awarding:
• US$3,614.00 as sickness allowance.
• US$80,000.00 as permanent medical unfitness benefits.
• Attorney’s fees.
• Respondents appealed the Labor Arbiter’s decision to NLRC asserting:
• Payment had already been made for the sickness allowance.
• The award for permanent disability was not supported due to a lack of documentary proof regarding the CBA and petitioner’s membership in AMOSUP.
• The NLRC dismissed respondents’ appeal on August 20, 2003, and denied a subsequent motion for reconsideration.
• Respondents then filed a petition for certiorari before the Court of Appeals.
• In the Court of Appeals Decision dated May 31, 2005:
• The earlier NLRC and Labor Arbiter findings were largely upheld regarding the awarding of permanent medical unfitness benefits.
• Evidence showing petitioner’s receipt of sickness allowance (amounting to P178,468.32) was admitted, which led to its denial in the current award.
• The supposed membership in AMOSUP and the purported CBA evidence were determined insufficient to sustain the award of US$80,000.00, leading to the computation of benefits solely under the POEA Standard Contract.
• The computed benefits were determined at US$7,465.00 (US$50,000.00 multiplied by 14.93% disability).
• An award of attorney’s fees was also denied.
• On July 14, 2005, the Court of Appeals issued a Resolution denying petitioner’s motion for reconsideration, ruling the late submission of his CBA evidence as untimely and prejudicial to respondents’ due process.
• Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari, raising:
• The alleged grave error in not admitting evidence of his membership with AMOSUP and the Singapore Maritime Officers’ Union.
• Claims of bias by the Court of Appeals in favor of respondents.

Issue:

• Whether the Court of Appeals committed grave error by not admitting and considering petitioner’s belatedly submitted evidence, which purportedly proves his membership in AMOSUP and the Singapore Maritime Officers’ Union, thereby entitling him to a higher amount (US$110,000.00) of disability benefits.

• Whether the Court of Appeals was biased in its proceedings by showing leniency toward the respondents (employers) while strictly applying the rules against petitioner (employee), particularly concerning the evaluation of evidence and the application of procedural rules.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)