Facts:

This case revolves around Benedicto O. Buenaventura, Jr., who filed a petition for review on certiorari against Career Philippines Shipmanagement, Inc., Columbia Shipmanagement Ltd., and Sampaguita D. Marave. The petition was deemed necessary after the Court of Appeals (CA) reversed and set aside the Labor Arbiter's (LA) ruling, which had found that Buenaventura was entitled to total and permanent disability benefits under their Collective Bargaining Agreement (CBA). Buenaventura entered into a nine-month contract as a laundryman on July 11, 2012, after being declared fit for duty through a pre-employment medical examination. While on board MV Columbus 2, Buenaventura suffered an injury on December 25, 2012, when he slipped and hit his left shoulder against a door of a washing machine. He reported this incident to the ship’s doctor, who treated him but could not alleviate his pain. Upon arriving in Manila, he was sent for further medical evaluation, where it was suspected th

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Facts:

Employment and Contractual Background

• On July 11, 2012, petitioner Benedicto O. Buenaventura, Jr. entered into a nine-month contract with respondent Columbia Shipmanagement Ltd., through its local agent, Career Shipmanagement, Inc., as a laundryman.
• Buenaventura was declared fit for duty after a pre-employment medical examination and subsequently went on board MV Columbus 2.

Incident and Initial Medical Attention

• On December 25, 2012, Buenaventura allegedly slipped and hit his left shoulder on the door of a washing machine while performing his laundry duties.
• He reportedly immediately informed the ship doctor about his injury and was given medication, although the pain persisted.

Subsequent Medical Evaluation and Treatment

• During a stopover in Manila, Buenaventura was accompanied by the ship doctor to St. Luke’s Medical Center for further laboratory tests. Initial findings even spurred a suspicion of coronary artery disease, prompting recommendations for repatriation.
• To determine the cause of his persistent shoulder pain, he underwent a series of examinations and laboratory tests by company-designated doctors, including a Magnetic Resonance Imaging study which ruled out serious heart ailments but revealed:

- Superior labral tear - Degenerative changes, superior glenoid rim - Mild supraspinatus tendinosis - Mild acromioclavicular joint hypertrophy

Professional Medical Assessments and Dispute

• On July 8, 2013, a company-designated physician issued a final report, assigning a disability grading of 12 for the neck and 11 for the shoulder.
• Subsequently, independent physicians issued their own Medical Certificates, stating that Buenaventura was unfit to resume work as a seaman; however, respondents were not informed of this independent evaluation.
• Buenaventura continued receiving treatment from company-designated doctors until August 2013.

Filing the Disability Benefits Claim and Procedural Posture

• On February 14, 2014, Buenaventura filed a complaint for disability benefits, claiming his condition resulted from an accident suffered while on board MV Columbus 2.
• Respondents denied liability under the Collective Bargaining Agreement (CBA), arguing that the injury did not stem from an accident and that Buenaventura failed to comply with the prescribed procedures under both the CBA and the POEA-SEC regarding disputed medical assessments.

Decisions by Lower Labor and Adjudicatory Bodies

• The Labor Arbiter (LA), in its Decision dated July 22, 2014, ruled in favor of Buenaventura, finding him to be suffering from total and permanent disability (disability grading 1) and ordered the respondents to pay US$125,000.00 plus attorney’s fees.
• The National Labor Relations Commission (NLRC) affirmed the LA ruling in its Decision dated September 22, 2014 and denied the respondents’ appeal for lack of merit.
• Respondents’ motion for reconsideration was denied in a Resolution dated October 16, 2014.

Court of Appeals (CA) Review

• The CA, in its Decision dated December 18, 2015, granted the petition for certiorari, set aside the NLRC ruling, and held that Buenaventura failed to prove that his injury was caused by an accident.
• The CA also stressed that Buenaventura had not complied with the procedure of referring conflicting medical assessments to a third doctor for a binding opinion.
• Buenaventura’s subsequent motion for reconsideration was denied in a Resolution dated April 18, 2016, leading to the current petition for review.

Issue:

Whether or not petitioner's injury constitutes a work-related injury arising out of and in the course of his employment.

• Does the nature and timing of the injury, as well as the context in which it occurred, satisfy the “arising out of and in the course of employment” requirement under the POEA-SEC and the CBA?

Whether Buenaventura sufficiently proved that an accident occurred on board MV Columbus 2.

• Consideration is given to the absence of an incident report in the ship’s log and the Master’s report.
• Evaluating if the medical findings and conclusions based on company-designated physicians’ reports can stand as proof of an accident.

Whether failure to comply with the prescribed dispute resolution mechanism (i.e., referral to a third doctor in case of conflicting assessments) precludes Buenaventura from claiming the benefits rendered by independent physicians.

• The issue examines the procedural consequences under the POEA-SEC when divergent medical opinions arise.

• The overall entitlement of Buenaventura to disability benefits under the applicable instruments governing the employment relationship, namely the CBA and the POEA-SEC.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)