Title
C.F. SHARP CREW MANAGEMENT, INC. vs. TAO K
Case
G.R. No. 193679
Decision Date
Jul 18, 2012
Seafarer filed for permanent disability benefits while still undergoing treatment; SC ruled no cause of action, illness not proven work-related, and inconsistent claims.
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Case Digest (G.R. No. 193679)

Facts:

Employment Contract and Onboarding:
Petitioner C.F. Sharp Crew Management, Inc. (C.F. Sharp), a domestic corporation engaged in recruiting Filipino seafarers, entered into a 10-month employment contract with respondent Joel D. Taok (Taok) on behalf of Norwegian Cruise Line, Ltd. Taok was employed as a cook on the vessel M/V Norwegian Sun with a monthly salary of US$396.00. The contract included the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC). Taok boarded the vessel on January 8, 2006.

Medical Condition and Treatment:
On July 25, 2006, Taok experienced pain in his left parasternal area, dizziness, difficulty in breathing, and shortness of breath. He was taken to Prince Rupert Regional Hospital in Canada, where he was diagnosed with atrial fibrillation. He was advised to take medication and undergo further tests. On August 5, 2006, Taok was repatriated to the Philippines.

Post-Repatriation Medical Evaluation:
Upon arrival in the Philippines on August 7, 2006, Taok underwent medical evaluation at Sachly International Health Partners, Inc., a company-designated clinic. On September 18, 2006, he was diagnosed with cardiomyopathy, ischemic vs. dilated (idiopathic). Taok was advised to continue treatment but filed a complaint for total and permanent disability benefits on September 19, 2006, before completing his treatment.

Labor Arbiter’s Decision:
The Labor Arbiter dismissed Taok’s claim for permanent disability benefits, ruling that Taok had no cause of action at the time of filing since he was still undergoing treatment and no disability assessment had been made. However, Taok was awarded US$1,584.00 as sickness wages for four months.

Appeal to NLRC and CA Decision:
Taok appealed to the National Labor Relations Commission (NLRC), which upheld the Labor Arbiter’s decision. The Court of Appeals (CA), however, reversed the NLRC’s decision, awarding Taok US$60,000.00 as permanent and total disability benefits plus sickness wages.

Issue:

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Ruling:

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Ratio:

  1. Timeframe for Disability Claims: Under the POEA-SEC and the Labor Code, a seafarer is considered temporarily and totally disabled for up to 120 days, which may extend to 240 days if further medical treatment is required. A claim for permanent disability benefits cannot arise until after this period or upon a final assessment by the company-designated physician.
  2. Burden of Proof on Work-Relatedness: The claimant must prove that the illness is work-related. Taok failed to establish this connection, and the Court found his evidence insufficient.
  3. Inconsistency in Claims: Filing a claim for permanent disability benefits while still in a state of temporary disability is inconsistent with the legal framework. Taok’s claim for sickness wages was incompatible with his pursuit of permanent disability benefits.


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