Title
Gere vs. Anglo-Eastern Crew Management Phils., Inc.
Case
G.R. No. 226656
Decision Date
Apr 23, 2018
A Filipino seafarer seeks disability benefits from his employer after suffering an accident, leading to a court ruling in his favor due to the company-designated physician's failure to issue a final medical assessment within the prescribed period, resulting in the seafarer being awarded disability benefits of US$60,000.
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Case Digest (G.R. No. 226656)

Facts:

  • In the consolidated cases of G.R. Nos. 226656 and 226713, Arnel T. Gere, a Filipino seafarer, filed a petition against his employer, Anglo-Eastern Crew Management Phils., Inc., and its principal, Anglo-Eastern Crew Management (Asia), Ltd.
  • Gere was employed as an able seaman on the vessel "MV JENNY N" under a contract that included a Collective Bargaining Agreement (CBA) between the Associated Marine Officers' and Seamen's Union of the Philippines (AMOSUP) and the respondents.
  • On January 4, 2014, Gere suffered an accident while performing his duties, leading to a "Closed Complete Fracture, Right Radius, Undisplaced."
  • He was repatriated to the Philippines for medical treatment and underwent various medical procedures until August 27, 2014.
  • The company-designated physician issued an interim disability grading of "Grade 10 loss of grasping power" on April 28, 2014, and a final disability grading of "Grade 10 ankylosed wrist in normal position" on August 12, 2014.
  • Gere claimed he was not informed of these assessments and consulted his personal physician, who declared him permanently unfit for sea duties with a "Grade 8 impediment."
  • The Panel of Voluntary Arbitrators awarded Gere total and permanent disability benefits, which the Court of Appeals (CA) later modified, reducing the amount to US$60,000.
  • Both parties sought further review by the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that the company-designated physician did not issue a final medical assessment within the prescribed period.
  2. The Court found that the referral to a neutral third-party physician is mandatory, but this process could not commence as Gere was not properly informed of the company-designated physician's assessment.
  3. ...(Unlock)

Ratio:

  • The Supreme Court emphasized the importance of due process in informing the seafarer of his medical assessment.
  • The company-designated physician must not only issue but also give the medical assessment to the seafarer, ensuring the seafarer is fully informed.
  • The failure to properly notify Gere meant that the ...continue reading

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