Facts:

The case at hand, Mon C. Anuat vs. Pacific Ocean Manning, Inc., involves a petition for review on certiorari challenging the decisions of the Court of Appeals dated 10 March 2015 and 6 October 2015, concerning the claims of the petitioner Anuat for total and permanent disability benefits following an incident during his employment as an able seaman. Anuat was hired by Pacific Ocean Manning, Inc., a corporation incorporated under Philippine law, on 7 February 2011. His employment was under a standard employment contract from the Philippine Overseas Employment Administration (POEA) and lasted for nine months with a monthly salary of US$662. Anuat underwent a pre-employment medical examination and was deemed "Fit for Sea Duty." On 10 February 2011, he joined the vessel M/V Satigny in Norfolk, USA. Unfortunately, on 19 May 2011, during unloading operations in Cabello, Venezuela, Anuat suffered injuries after falling on the vessel's deck while connecting a crane hook, r

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Facts:

Employment and Incident

• Mon C. Anuat was hired as an able seaman by Pacific Ocean Manning, Inc. on February 7, 2011, under a POEA standard employment contract with a nine‐month term and a basic monthly salary of US$662.00.
• Prior to deployment, Anuat underwent a pre-employment medical examination conducted by Pacific’s company-designated physician and was declared “Fit for Sea Duty.”
• On February 10, 2011, Anuat departed for Norfolk, United States, to report aboard the vessel M/V Satigny.
• On May 19, 2011, while engaged in unloading operations in the port of Cabello, Venezuela, Anuat sustained injuries after falling from the vessel’s deck. His injuries included trauma to the neck, back, and knee, with diagnoses of head injury, whiplash, and left knee trauma.
• Following treatment in Venezuela and subsequent medical advice, Anuat was medically repatriated to the Philippines on May 22, 2011.

Medical Treatment and Follow-Up

• Upon arrival in the Philippines on May 24, 2011, Anuat was referred to Dr. Nicomedes Cruz, Pacific’s company-designated physician, for further assessment.
• Medical reports dated July 15 and July 22, 2011, recommended that Anuat undergo Magnetic Resonance Imaging (MRI) on his spine and left knee.
• MRI results on August 1 and 2, 2011, revealed persistent issues: a lumbosacral disc issue with an annular tear/fissure and an inferior surface tear of the medial meniscus in his left knee.
• A subsequent medical report dated September 22, 2011, identified ongoing injuries including blunt trauma to the back, muscular spasm of the cervical muscles, and a meniscus tear, with a recommendation for knee surgery and a follow-up appointment on September 30, 2011.
• Anuat did not return for the follow-up; instead, he later claimed that his injuries had rendered him unable to continue his duties as an able seaman.

Filing of the Disability Claim and Early Dispute

• On October 26, 2011—160 days from the onset of his work-related injury—Anuat filed a complaint with the Labor Arbiter seeking total and permanent disability benefits, reimbursement of medical expenses, sickness allowance, damages, and attorney’s fees.
• Anuat contended that his spinal and knee injuries prevented him from performing his usual work and that he was entitled to total and permanent disability benefits, arguing that more than 120 days had elapsed since his medical repatriation.
• Pacific, in its position papers and replies, maintained that Anuat sustained only a partial and permanent disability, as evidenced by the “Grade 10” and “Grade 11” ratings issued by its company-designated physician. Pacific argued that the disability grading should be the basis for any compensation, not merely the elapsed time.

Proceedings in Labor Arbiter and NLRC

• The Labor Arbiter, in a decision dated September 24, 2012, ruled in favor of Anuat by granting him total and permanent disability benefits based on his inability to work for over 120 days, applying the POEA schedule that amounted to US$60,000.00.
• Anuat filed a Memorandum of Partial Appeal with the NLRC on October 22, 2012, asserting that the Collective Bargaining Agreement (CBA) should determine his disability compensation.
• Pacific submitted its Memorandum of Appeal; however, its appeal was deemed not perfected because the required appeal fees were paid beyond the reglementary period.
• The NLRC, on January 31, 2013, modified the Labor Arbiter’s decision to adhere to the CBA, awarding Anuat disability benefits set at US$89,000.00, which included a provision for attorney’s fees as initially claimed, though later adjustments would be made.

Court of Appeals Proceedings

• Pacific filed a Petition for Certiorari with the Court of Appeals (CA) on May 24, 2013, while Anuat filed comments on August 12, 2013.
• In a decision dated March 10, 2015, the CA granted Pacific's petition for certiorari. The CA held that Anuat’s claim for total and permanent disability was premature because further medical treatment was still in progress under the extended 240-day period provided by law.
• The CA clarified that while Anuat had been undergoing treatment and was advised for a follow-up on September 30, 2011, his filing on October 26, 2011, did not meet the requirement for the lapse of the extended period.
• Consequently, the CA ruled that Anuat was not entitled to total and permanent disability benefits but was instead entitled to partial and permanent disability benefits based on the “Grade 10” and “Grade 11” ratings.
• The CA also denied Anuat’s claim for attorney’s fees, concluding that there was no evidence of bad faith on Pacific’s part.

Issue:

Entitlement to Disability Benefits

• Whether Anuat is entitled to total and permanent disability benefits under the Labor Code given that his claim was filed within the 240-day extended medical treatment period.
• Whether the definition and conditions for declaring permanent disability – as set forth in the Labor Code and the Amended Rules on Employees’ Compensation – had been satisfied.

Entitlement to Attorney’s Fees

• Whether Anuat is entitled to claim attorney’s fees based on allegations of Pacific’s bad faith or other misconduct.
• Whether the procedural and evidentiary requirements for awarding attorney’s fees have been met.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)