Case Digest (G.R. No. L-19671) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rosell R. Arguilles v. Wilhelmsen Smith Bell Manning, Inc., petitioner Rosell R. Arguilles entered into a June 15, 2016 Contract of Employment with Wilhelmsen Smith Bell Manning, Inc. on behalf of Wilhelmsen Ship Management Ltd. to serve as an Ordinary Seaman aboard M/V Toronto for six months. He passed pre-boarding medical exams and commenced duty on July 24, 2016. On December 26, 2016, while playing basketball in the vessel’s recreation area during off-duty hours, he suffered a suspected torn Achilles tendon in his left ankle. A ship master’s Injury/Illness Report led to repatriation on January 18, 2017. In the Philippines, he underwent MRI, was diagnosed with a high-grade Achilles tendon tear, received surgical repair on February 6, 2017 at Cardinal Santos Medical Center, and completed 49 physical therapy sessions through June 23, 2017. Respondents halted treatment on June 28, 2017. An independent physician declared him unfit for sea duty. Petitioner filed for disability b Case Digest (G.R. No. L-19671) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On June 15, 2016, petitioner Rosell R. Arguilles entered into a six-month Contract of Employment with Wilhelmsen Smith Bell Manning, Inc. (Wilhelmsen Manning) on behalf of Wilhelmsen Ship Management Ltd. (WSML) as Ordinary Seaman on board M/V Toronto.
- While playing basketball on board on December 26, 2016, petitioner suffered a left Achilles tendon injury; he was repatriated January 18, 2017, underwent MRI, surgery (February 6), and 49 physical therapy sessions until June 23, 2017.
- Company-designated physicians ceased treatment on June 28, 2017; independent physician Dr. Catapang declared him unfit for sea duty; petitioner claimed disability benefits under the NSA-AMOSUP/NSU CBA.
- Procedural history
- Labor Arbiter Renaldo Hernandez (Apr 30, 2018) found the injury work-related under the Bunkhouse Rule and awarded US $90,000 total and permanent disability benefits plus PHP 450,000 moral/exemplary damages and 10% attorney’s fees.
- NLRC First Division (Oct 17, 2018) partly granted respondents’ appeal, reducing benefits to US $9,405 and damages to PHP 100,000; on reconsideration (Jan 23, 2019) it reversed itself and dismissed petitioner’s claim for lack of work-relatedness.
- Court of Appeals (Jan 24, 2020; R-M denied Nov 9, 2020) denied petitioner’s certiorari petition, affirmed NLRC dismissal; petitioner filed Rule 45 petition before the Supreme Court.
Issues:
- Whether the ankle injury sustained during off-duty basketball on board is work-related and compensable under the POEA SEC and NSA-AMOSUP/NSU CBA.
- Whether respondents’ failure to secure a final medical assessment within the 120-/240-day period presumes total and permanent disability.
- Whether corporate officers of Wilhelmsen Manning are jointly and severally liable for the money awards under R.A. 8042.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)