Case Digest (G.R. No. 208981)
Facts:
- C.F. Sharp Crew Management, James Fisher Tankship Ltd., and Mr. Rafael T. Santiago are the petitioners.
- Jimmy G. Jaicten is the respondent.
- Jaicten was employed as a Bosun on the M/V Cumbrian Fisher on April 30, 2008, under a nine-month contract.
- He was declared fit for work during his pre-employment medical examination.
- On October 5, 2008, Jaicten experienced chest pains and was diagnosed with non-ST myocardial infarction in the UK.
- He underwent treatment, including coronary arteriography and balloon dilation with stenting.
- Jaicten was repatriated on October 30, 2008, and referred to Sachly International Health Partners Clinic (SIHPC).
- On January 7, 2009, company-designated physician Dr. Susannah Ong-Salvador certified him as fit to work.
- Jaicten sought a second opinion from Dr. Efren Vicaldo, who declared him unfit for sea duties.
- He filed a complaint for total and permanent disability benefits, moral and exemplary damages, and attorney's fees.
- The Labor Arbiter dismissed his complaint, citing Jaicten's signing of the Certificate of Fitness to Work.
- The NLRC reversed this decision, granting Jaicten benefits based on Dr. Vicaldo's assessment.
- The Court of Appeals upheld the NLRC's ruling, leading the petitioners to appeal to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioners.
- The Court granted the petition and reversed the NLRC and Court of Appeals decisions.
- The Labor Arbiter's ruling, whi...(Unlock)
Ratio:
- The Supreme Court emphasized the importance of assessments by company-designated physicians.
- Jaicten's second opinion from Dr. Vicaldo lacked supporting diagnostic tests and was based on a single examination.
- The evaluations by Dr. Ong-Salvador were deemed comprehensive and thorough.
- Jaicten's signing of the Certificate of Fitness to Work released the petitioners from liability, with no evidence of coercion.
- His failure to follow the procedure for a third doctor'...continue reading
Case Digest (G.R. No. 208981)
Facts:
The case involves C.F. Sharp Crew Management, James Fisher Tankship Ltd., and Mr. Rafael T. Santiago as petitioners against Jimmy G. Jaicten, the respondent. The events leading to the case began on April 30, 2008, when Jaicten was employed as a Bosun aboard the M/V Cumbrian Fisher for a nine-month contract. He was declared fit for work during his pre-employment medical examination. However, on October 5, 2008, he experienced chest pains and was subsequently diagnosed with non-ST myocardial infarction at Belfast City Hospital in the United Kingdom. Following treatment that included coronary arteriography and balloon dilation with stenting, he was repatriated on October 30, 2008, and referred to Sachly International Health Partners Clinic (SIHPC). On January 7, 2009, the company-designated physician, Dr. Susannah Ong-Salvador, certified Jaicten as fit to work. However, upon seeking a second opinion from his own doctor, Dr. Efren Vicaldo, Jaicten was declared unfit for sea duties. In response, he filed a complaint for total and permanent disability benefits, along with claims for moral and exemplary damages, and attorney's fees. The Labor Arbiter dismissed his complaint, stating that Jaicten's signing of the Certificate of Fitness to Work confirmed his fitness and barred him from claiming benefits. The National Labor Relations Commission (NLRC) later reversed this d...