G.R. No. 225899 - Esteva vs. Wilhelmsen Smith Bell Manning, Inc.

On January 26, 2012, Wilhelmsen Smith Bell Manning, Inc. (Smith Bell Manning) hired Jessie C. Esteva as a seafarer for a nine‑month contract with a basic monthly salary of US$675.00.
Esteva was deployed on April 15, 2012, after undergoing the required medical examination and being pronounced fit to work.
On April 16, 2012, he boarded the vessel Ikan Bagang.

Sometime in June 2012, while aboard the vessel, Esteva began experiencing severe back pains.
As the vessel arrived in China on June 20, 2012, he requested assistance from the vessel’s Master in obtaining medical help.
On June 24, 2012, Esteva visited a small clinic for x‑ray examination and received oral and topical pain relievers.

On October 5, 2012, while the vessel was at Richards Bay, South Africa, Dr. W. Watson diagnosed Esteva with lumbar disc prolapse, declaring him temporarily totally disabled and unfit for work; immediate repatriation was recommended.
Wilhelmsen Ship Management sent a letter requesting that Esteva be examined by a company‑designated physician in the Philippines.

Upon his return on October 7, 2012, Esteva underwent several examinations at the Metropolitan Medical Center.
His x‑ray revealed osteodegenerative changes in the lumbar spine.
On April 3, 2013, company‑designated physician Dr. Mylene Cruz‑Balbon issued a Medical Certificate indicating treatment for Pott’s disease (a form of tuberculosis of the spine) and prescribed a treatment of at least one year, with a suggested disability grading of Grade 8 (2/3 loss of lifting power).
On July 19, 2013, Dr. Cruz‑Balbon reaffirmed the findings by issuing another Medical Certificate confirming both Pott’s disease and disc protrusion.

On September 13, 2013, Esteva consulted Dr. Maricar P. Reyes‑Paguia, who reported multilevel lumbar spondylosis, disc issues, and narrowing of neuroforamina.
Subsequently, on a date allegedly noted as September 17, 2013 (later clarified by petitioner as July 13, 2013), Esteva consulted an orthopedic surgeon, Dr. Alan Leonardo R. Raymundo, whose Medical Report indicated:

The patient was ambulatory but limped with pain on movement.
Positive findings on physical examinations (e.g., positive straight leg raise test, muscle weakness).
An explanation that his condition precluded a return to his previous occupation as an able-bodied seaman.

Based on these conflicting medical opinions, Esteva filed a complaint for total and permanent disability benefits.
The initial labor tribunal decision (January 29, 2014) granted benefits for disability compensation, sickness allowance, and attorney’s fees, giving weight to the private doctors’ findings over that of the company‑designated physician.
The National Labor Relations Commission affirmed the award on June 18, 2014, noting that Esteva was essentially rendered permanently disabled, while also emphasizing the company‑designated physician’s assessment related to treatment duration and loss of lifting power.

Smith Bell Manning filed a Petition for Certiorari after the NLRC decision; the Court of Appeals in its March 22, 2016 Decision annulled the lower tribunal rulings and upheld the Grade 8 rating conferred by Dr. Cruz‑Balbon, thereby limiting the award to partial disability benefits and sickness allowance.
The CA emphasized the significance of the POEA Standard Employment Contract’s Section 20‑A, which provides that if there is a dispute regarding the company‑designated physician’s assessment, the seafarer must request a third doctor’s evaluation.
Esteva contended that his failure to refer to a third doctor was not a breach because respondents had not informed him about the existence or the content of the company‑designated physician’s assessment.
Esteva argued that the company‑designated doctor’s findings were biased and that his injury, having incapacitated him for over 240 days, should be deemed total and permanent.
Respondents maintained that the referral to a third doctor is mandatory, and Esteva’s premature filing of the complaint invalidated his challenge to the company‑designated physician’s assessment.
Subsequent submissions and responses by both parties led to a review by this Court, noting issues regarding factual determinations, mandatory procedural rules, and the appropriate weighing of medical evidence.

Whether the Court of Appeals erred in conducting its own factual determination and substituting the findings of the labor tribunals when evaluating Esteva’s claims.
Whether, under the POEA Standard Employment Contract, the referral to a third doctor was mandatory and whether Esteva’s failure to invoke this procedure precluded his entitlement to total disability benefits.
Whether or not Esteva is entitled to:

Whether Esteva is entitled to moral and exemplary damages, as well as attorney’s fees, given the allegedly bad faith conduct of the respondents in handling his medical assessment and disability benefits.