Title
Bunayog vs. Foscon Shipmanagement, Inc., Green Maritime Co., Ltd., Evelyn M. Defensor
Case
G.R. No. 253480
Decision Date
Apr 25, 2023
Seafarer Bunayog's disability claim denied after employer's doctor found him fit. Employer ignored seafarer's valid request for third doctor. Court ruled employer's doctor's findings credible due to lack of basis in seafarer’s doctor's report.
A

Case Digest (G.R. No. 183804)

Facts:

  • Employment and Medical Condition
    • Petitioner Teodoro B. Bunayog was employed by Foscon Shipmanagement, Inc., on behalf of its foreign principal Green Maritime Co., Ltd., as chief cook onboard the vessel MIT Morning Breeze for nine months.
    • On July 31, 2016, petitioner experienced cough, fever, and difficulty breathing while onboard.
    • Diagnosed in Japan on August 2, 2016, with left lung pneumonia and declared unfit for sea duty.
    • Repatriated to the Philippines on August 4, 2016, and referred immediately to a company-designated physician.
  • Medical Evaluations and Treatment
    • Company-designated physician diagnosed pneumonia with recurrent pleural effusion and treated petitioner until September 28, 2016.
    • On September 28, a company-designated physician declared petitioner fit to resume work.
    • Petitioner consulted his own doctor, Dr. Noel C. Gaurano, who declared him unfit for sea duty due to pleural effusion.
  • Communication and Legal Actions
    • On November 10, 2016, petitioner sent a letter to respondent Foscon's president, Evelyn M. Defensor, informing her of the contrary medical findings and willingness to undergo a third medical examination to resolve the conflict.
    • Respondents did not respond to the letter.
    • Petitioner filed a complaint for total and permanent disability benefits amounting to USD 60,000.00, plus transportation expenses and attorney’s fees.
  • Labor Arbiter and NLRC Decisions
    • Labor Arbiter dismissed the complaint, favoring the company-designated physician's findings over the petitioner's physician.
    • NLRC affirmed the Labor Arbiter's dismissal, ruling that referral to a third doctor requires mutual agreement, which was absent.
  • Court of Appeals Decision
    • The CA affirmed NLRC's decision, excluding the petitioner’s physician’s report as it lacked medical tests and was based on general observation.
    • The petition for reconsideration was denied.
  • Supreme Court Involvement
    • Petitioner filed a Petition for Review on Certiorari seeking total and permanent disability benefits.

Issues:

  • Whether petitioner is entitled to total and permanent disability benefits.
  • Whether attorney’s fees and moral damages should be awarded.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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