Title
Belchem Philippines, Inc. vs. Zafra, Jr.
Case
G.R. No. 204845
Decision Date
Jun 15, 2015
Seafarer injured on duty, unable to work for over 240 days without definitive medical assessment, deemed permanently and totally disabled, awarded US$60,000.
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Case Digest (G.R. No. 204845)

Facts:

Employment and Injury

  • Eduardo A. Zafra, Jr. (Zafra) was hired as a "wiper" by Belchem Philippines, Inc. (Belchem) through its local manning agent, United Philippine Lines (UPL), for a four-month contract.
  • On September 30, 2009, Zafra sustained injuries to his left knee after falling while checking for leaks in the ship's engine room.
  • He was initially examined in Amsterdam on October 16, 2009, and repatriated to the Philippines on October 22, 2009, for further medical treatment.

Medical Treatment and Assessments

  • Upon arrival in the Philippines, Zafra was examined by the company-designated physician, Dr. Robert D. Lim, who diagnosed him with "Probable Medial Meniscal Tear, Left Knee" and "Anterior Cruciate Ligament (ACL) Tear, Left Knee," requiring surgery.
  • On January 5, 2010, Zafra underwent "Arthroscopic ACL Reconstruction" and was confined for over a week, followed by rehabilitation.
  • On January 20, 2010, Dr. Lim gave an interim assessment of Grade 10 disability.
  • On April 19, 2010, Dr. William Chuasuan, Jr., suggested a disability grading of 20% of Grade 10, equivalent to US$3,590.73 under the POEA-SEC.

Legal Proceedings

  • On July 5, 2010, Zafra filed a complaint for permanent total disability benefits, moral and exemplary damages, and attorney's fees.
  • The Labor Arbiter (LA) awarded Zafra US$3,590.73, but the National Labor Relations Commission (NLRC) reversed this decision, awarding Zafra US$60,000.00 as permanent total disability benefits.
  • The Court of Appeals (CA) affirmed the NLRC's decision, prompting the petitioners to file a petition for review with the Supreme Court.

Issue:

  1. Whether Zafra is entitled to permanent total disability benefits of US$60,000.00 or only partial disability benefits of US$3,590.73.
  2. Whether the CA erred in affirming the NLRC's award of attorney's fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled that Zafra's inability to work for over 240 days without a definitive assessment from the company-designated physician rendered him permanently and totally disabled, entitling him to US$60,000.00 in benefits. The award of attorney's fees was also upheld.


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