G.R. No. 219495 - Cabatan vs. Southeast Asia Shipping Corp.

Case Digest (G.R. No. 219495)
Expanded Legal Reasoning Model

Facts:

Procedural and Employment Background

Petitioner Reynaldo P. Cabatan was employed as an oiler by Southeast Asia Shipping Corp. (SEASCORP) on behalf of its principal, Maritime Management Services, from 2006 to 2010.
Prior to deployment, Cabatan underwent a Pre-Employment Medical Examination (PEME) and was certified fit for sea duty.
He boarded M/V BP Pioneer on January 30, 2010 under a three-month contract.

Incident and Immediate Aftermath On Board

On March 29, 2010, during a 12‑hour duty, while carrying spare parts and a heavy connecting rod amid big waves, the vessel swayed; Cabatan bent down and nearly fell to his knees.
He immediately experienced excruciating pain in his scrotal/inguinal area and continued to work despite feeling pain and numbness in his left leg down to his foot.
After duty, Cabatan took a pain reliever and visited the ship’s clinic where the on‑board doctor documented his condition in a Report of Illness; the doctor advised bed rest and ruled out hernia and trauma.

Post-Employment Medical Evaluations and Medical Findings

Cabatan’s contract expired on May 25, 2010, at which point he disembarked at Takoradi, Ghana and was subsequently repatriated to the Philippines.
Believing his pain was normal, he rested for about a month as per the doctor's initial advice.
On a subsequent possible deployment, Cabatan underwent a second PEME at the company‑accredited Merita Diagnostic Clinic where he informed the examiner of his on‑board injury.

The clinic’s findings on July 2, 2010 noted perineal pain while walking, lumbar-sacral x-ray findings (retrolistheses at L2 over L3, osteodegenerative changes, sacralization of L5), and recommendations for further investigations (EMG NCV and MRI).

Further diagnostic examinations followed:

On July 30, 2010, an MRI of the lumbosacral spine showed central canal and neural foraminal stenosis (L4‑L5 and L5‑S1) due to disc protrusion, ligamentum flavum thickening, facet arthropathy, disc bulging at L2‑L3 and L3‑L4, lumbar osteophytes, posterior annular tears, and Grade I spondylolisthesis at L4‑L5.
An EMG NCV confirmed a mild chronic lumbar radiculopathy affecting the L4‑5 and L5‑S1 nerve roots.
Consultation with orthopedic and spine surgeons (including Dr. Detabali and Dr. David M. Cabatan, Jr.) led to the diagnosis of spinal stenosis and Grade I spondylolisthesis, with recommendations for laminectomy and instrumented posterolateral fusion. The estimated cost of surgery was P473,000.00.

Filing of the Claim and Subsequent Allegations

On March 1, 2011, Cabatan filed a complaint against SEASCORP and related respondents, seeking permanent and total disability benefits, along with moral, exemplary damages, and attorney’s fees.
Respondents argued that Cabatan:

Had been certified fit for sea duty during his last PEME.
Did not report for the mandatory post‑employment medical examination immediately after repatriation, as required under the Philippine Overseas Employment Administration Standard Employment Contract (POEA‑SEC).

Rulings at the Labor Arbiter and NLRC Levels

The Labor Arbiter (LA) ruled in favor of Cabatan in its August 31, 2011 decision, awarding him permanent and total disability compensation equivalent to $60,000.00 plus attorney’s fees of 10% of the judgment.

The LA found that the injury sustained during duty must be compensable and that the failure to undergo the post‑employment examination was inapplicable because Cabatan was repatriated due to contract expiration, not for medical reasons.

Respondents appealed, and the National Labor Relations Commission (NLRC) reversed the LA’s decision in its April 26, 2012 decision, dismissing Cabatan’s claim:

The NLRC held that evidence did not support Cabatan’s assertion that a work‑related injury led to a permanent and total disability.
It emphasized Cabatan’s failure to comply with the mandatory three‑day reporting requirement for a post‑employment medical examination as prescribed under Section 20(B)(3) of the POEA‑SEC.

A subsequent motion for reconsideration by Cabatan was denied by the NLRC in its June 18, 2012 resolution.

Court of Appeals (CA) Proceedings

Cabatan then filed a petition for certiorari before the CA, contending:

The failure to comply with the three‑day reporting requirement should not bar his claim since his repatriation resulted from contract expiration, not a medical condition.
He argued that his work‑related injury or illness had been substantiated by the ship doctor’s Report of Illness.

In its January 23, 2015 decision, the CA denied his appeal on the ground that non‑compliance with the mandatory reporting requirement forfeited his right to claim disability benefits.
A subsequent Motion for Reconsideration by Cabatan was also denied by the CA in its July 20, 2015 resolution.

Issues Raised in Cabatan’s Petition for Review on Certiorari

Cabatan alleged that the CA erred by:

Failing to consider the ship doctor’s Report of Illness which indicated that his “spondylolisthesis” was work‑related.
Ruling that the three‑day reporting requirement under the POEA‑SEC is an absolute rule, contrary to existing jurisprudence.

He further contended that he was entitled to disability compensation and attorney’s fees under Section 20(B)(6) of the 2000 POEA‑SEC based on the work‑related nature of his injury during employment.

Issues:

Whether Cabatan’s failure to report within the mandatory three‑day period for a post‑employment medical examination, as required under Section 20(B)(3) of the POEA‑SEC, bars his claim for disability benefits.

Issues relating to the interpretation and application of the three‑day reporting requirement.
Whether the rule is absolute or subject to exceptions (e.g., physical incapacitation).

Whether the injury or illness claimed by Cabatan (initially noted as scrotal/inguinal pain and later diagnosed as spondylolisthesis with spinal stenosis) can be attributed as work‑related and should be compensable under the POEA‑SEC and the Labor Code concept of permanent total disability.

The evidentiary sufficiency regarding the work‑related nature of the injury.
The relevance of the ship doctor’s Report of Illness versus later diagnostic findings.

Whether conflicting findings among the Labor Arbiter, NLRC, and CA warrant a re‑examination of the factual issues by the Supreme Court under its equity jurisdiction.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 219495) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 219495) Expanded Legal Reasoning Model

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Case Digest (G.R. No. 219495)
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Case Digest (G.R. No. 219495)
Expanded Legal Reasoning Model