Title
Arguilles vs. Wilhelmsen Smith Bell Manning, Inc.
Case
G.R. No. 254586
Decision Date
Jul 10, 2023
Seafarer injured during recreational basketball on vessel; injury deemed work-related under Bunkhouse Rule and Personal Comfort Doctrine. Disability lapsed into permanent due to lack of timely assessment, granting compensability.
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Case Digest (G.R. No. 254586)

Facts:

Employment Contract and Deployment
On June 15, 2016, Rosell R. Arguilles (petitioner) entered into a Contract of Employment with Wilhelmsen Smith Bell Manning, Inc. (Wilhelmsen Manning) on behalf of its principal, Wilhelmsen Ship Management Ltd. (WSML), to serve as an Ordinary Seaman on board the vessel M/V Toronto for six months. After passing a medical examination and being declared fit for sea duty, petitioner was deployed on July 24, 2016.

Injury and Repatriation
On December 26, 2016, while playing basketball during his free time, petitioner suffered a left ankle injury, suspected to be a torn Achilles tendon. He was medically repatriated to the Philippines on January 18, 2017, and referred to the company-designated physicians for evaluation and treatment.

Medical Treatment and Diagnosis
Petitioner underwent an MRI, which revealed a high-grade partial tear of the Achilles tendon and other related injuries. He underwent surgery on February 6, 2017, and was diagnosed with a "High Grade Achilles Tendon Tear, Left." Petitioner also attended 49 physical therapy sessions between February 13 and June 23, 2017.

Independent Medical Opinion
Petitioner consulted an independent physician, Dr. Rogelio P. Catapang, who declared him unfit for sea duty due to persistent pain and stiffness in his left foot and ankle, rendering him unable to perform his duties as a seafarer.

Labor Complaint
Petitioner filed a complaint for disability benefits, arguing that his injury was work-related under the Bunkhouse Rule and that respondents failed to provide a definitive assessment of his condition within 120 days, making his disability permanent and total under the parties' Collective Bargaining Agreement (CBA).

Issue:

Whether the Court of Appeals (CA) erred in affirming the National Labor Relations Commission's (NLRC) dismissal of petitioner’s claim for disability benefits on the ground that his injury was not work-related and, hence, not compensable.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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