Facts:

• Benedicto O. Buenaventura, Jr. entered a nine-month employment contract with Columbia Shipmanagement Ltd. as a laundryman on July 11, 2012.
• After passing a pre-employment medical exam, he boarded the MV Columbus 2.
• On December 25, 2012, he slipped and injured his left shoulder while on duty.
• He reported the injury to the ship's doctor and received medication but continued to experience pain.
• During a stopover in Manila, he was taken to St. Luke's Medical Center, where tests suggested coronary artery disease, leading to his repatriation.
• Upon return, medical examinations revealed a superior labral tear and other degenerative changes in his left shoulder.
• He underwent surgery on March 18, 2013, and received therapy until May 2013, during which he was paid a sickness allowance.
• On July 8, 2013, the company-designated physician graded his disability as 12 for the neck and 11 for the shoulder.
• Buenaventura later consulted independent physicians who declared him unfit for sea duty, but the respondents were unaware of these consultations.
• On February 14, 2014, he filed a complaint for disability benefits, claiming his condition resulted from an on-board accident.
• The respondents denied liability, asserting that the injury did not arise from an accident and that he failed to comply with procedures in the CBA and POEA-SEC.
• The Labor Arbiter ruled on July 22, 2014, that Buenaventura was entitled to total and permanent disability benefits.
• The NLRC upheld this decision on September 22, 2014.
• The Court of Appeals reversed the NLRC's ruling on December 18, 2015, stating Buenaventura failed to prove an accident and did not follow required procedures, leading to this petition for review.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in favor of Buenaventura, reversing the CA's decision.
• The Court held that Buenaventura's injury was work-related and entitled him to disability benefits.
• He was awa...(Unlock)

Ratio:

• The Court emphasized that the Labor Arbiter and NLRC correctly determined that Buenaventura's injury occurred during his employment, making it compensable under the CBA.
• The CA's dismissal for lack of evidence of an accident overlooked that Buenaventura's superior labral tear was consistent with his work as a laundryman.
• The injury arose out of and in the course of his employme...continue reading