Title
Dohle Philman Manning Agency, Inc. vs. Quinal Doble
Case
G.R. No. 223730
Decision Date
Oct 4, 2017
A seafarer injured on duty was declared fit by the company doctor within 210 days but claimed permanent disability. The Supreme Court ruled in favor of the employer, citing the seafarer's failure to follow mandatory third-doctor referral procedures under POEA-SEC, denying disability benefits.

Case Digest (G.R. No. 223730)
Expanded Legal Reasoning Model

Facts:

  • Consolidated Petitions and Parties
    • The case consolidates two petitions for review on certiorari under Rule 45 of the Rules of Court:
      • Petition No. 223730 – Filed by DOHLE Philman Manning Agency, Inc., DOHLE (IOM) Limited, and Capt. Manolo T. Gacutan (petitioners) against Julius Rey Quinal Doble (respondent).
      • Petition No. 223782 – Filed by respondent Julius Rey Quinal Doble against the petitioners.
    • The petitions question the decisions of the Court of Appeals (CA), which in turn affirmed and modified earlier decisions of the National Labor Relations Commission (NLRC) and the Labor Arbiter (LA).
  • Employment and Contractual Background
    • The respondent is a Filipino seafarer who signed a Contract of Employment with petitioner DOHLE (IOM) Ltd. through its manning agent, DOHLE Philman Manning Agency, Inc.
    • Key terms of the contract:
      • Position: Ordinary Seaman.
      • Duration: Nine months.
      • Basic Salary: US$350.00 per month.
      • Working Hours: Specified 44-hour work week with provisions on overtime and vacation leave with pay.
    • The respondent embarked from the Philippines on August 22, 2012, on board the vessel "MVTS JAKARTA."
  • Incidents and Medical Developments
    • First Incident:
      • Occurred in December 2012 while the vessel was approaching Hong Kong.
      • The respondent accidentally stepped on a mooring line while preparing to heave it, resulting in twisting of his right foot and an immediate fall.
      • He was examined by the ship’s doctor and declared fit to return to work.
    • Second Incident:
      • Occurred a few months later at the port of Karachi, Pakistan.
      • While pulling on a tug line, the vessel’s sudden movement caused his hands to get pulled and hit the bitts ballard.
      • Upon arrival at Hong Kong, he was referred for a medical consultation.
    • Medical Diagnosis and Treatment:
      • On April 11, 2013, after repatriation to the Philippines, the respondent underwent medical tests.
      • Diagnoses included:
        • Right ankle sprain.
        • Bilateral Carpal Tunnel Syndrome.
        • Osteochondral Defect of the Femoral Trochlea, Right Knee.
      • The respondent underwent surgery and physical therapy.
      • A company-designated physician initially issued an interim disability grade regarding the Carpal Tunnel Syndrome.
      • On November 8, 2013, a subsequent company-designated medical report declared him fit to work based on the surgeons’ assessments.
      • Contrarily, the respondent’s personal physician, Dr. Manuel Fidel Magtira, opined that the injuries had permanently reduced his pre-injury capabilities, rendering him unfit to resume his sea duties.
  • Administrative Proceedings and Awards
    • The respondent filed for disability benefits, claiming entitlement to expenses for medical treatment, transportation, and permanent total disability compensation.
    • The petitioners refused the disability benefits, prompting the case to be filed before the Labor Arbiter.
      • The LA rendered a Decision on November 27, 2014, finding the respondent permanently and totally disabled.
      • The award totaled US$90,882.00, which included disability compensation under the parties’ Collective Bargaining Agreement (CBA) plus an additional 10% for attorney’s fees.
    • The NLRC affirmed the LA decision in toto.
    • The CA, via a Petition for Certiorari under Rule 65, later affirmed the NLRC decision but modified:
      • Changing the basis of assessment from the CBA to the POEA-Standard Employment Contract (POEA-SEC).
      • Ordering an award of US$60,000.00 for permanent total disability benefits and attorney’s fees of ten percent (10%) of the total award.
    • Both parties filed motions for reconsideration before the CA, which were denied by its Resolution dated March 9, 2016.
    • Eventually, the case reached the Supreme Court for review.

Issues:

  • Fitness for Work and Disability Assessment
    • Whether the respondent is fit to work, based on differing medical opinions.
    • Whether his claim for disability benefits is justified given that the company-designated physician declared him fit to work.
  • Basis of the Award for Damages
    • Whether the appropriate basis for the award of damages should be the Collective Bargaining Agreement (CBA) or the POEA-SEC.
    • The implications of utilizing the 120-day rule versus following the company-designated assessment.
  • Award of Attorney’s Fees
    • Whether the CA erroneously awarded attorney’s fees to the respondent without factual or legal substantiation.
  • Procedural Compliance Regarding Medical Dispute Resolution
    • Whether the respondent’s failure to avail the mandatory procedure (i.e., referring conflicting medical assessments to a third doctor) undermines his claim.
    • Whether such procedural non-compliance renders the company-designated physician’s assessment final and binding.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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