Title
German Marine Agencies, Inc. vs. National Labor Relations Commission
Case
G.R. No. 142049
Decision Date
Jan 30, 2001
A seaman diagnosed with partial disability is entitled to benefits due to employer negligence in providing timely medical care, leading to permanent injury and entitlement to moral and exemplary damages.
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Case Digest (G.R. No. 142049)

Facts:

  • Froilan S. de Lara was employed as a radio officer by German Marine Agencies, Inc. and Lubeca Marine Management HK Ltd. on October 17, 1994.
  • In June 1995, while in New Zealand, de Lara fell ill, prompting his crewmates to inform the ship's master.
  • The master opted to continue the voyage to Manila instead of disembarking de Lara for medical care, worsening his condition over ten days.
  • Upon arrival in Manila, de Lara waited several hours for a docking slot before being admitted to Manila Doctors Hospital from June 24 to July 26, 1995.
  • After discharge, de Lara sought payment for disability benefits and unpaid sickness wages as per the Standard Employment Contract.
  • Despite initial payment, further compensation was not received, leading de Lara to file a complaint with the National Labor Relations Commission (NLRC).
  • On July 31, 1997, the labor arbiter ruled in favor of de Lara, awarding him $25,000 in disability benefits and $1,137 in sickness wage balance.
  • The NLRC affirmed this decision on July 29, 1998, and the Court of Appeals upheld it, awarding additional exemplary damages of P50,000.
  • The petitioners' motion for reconsideration was denied, resulting in the current appeal.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the NLRC's decision, confirming the petitioners' liability for de Lara's disability benefits.
  • The Court upheld the NLRC's findings regarding the sickness wage balance, affirming de Lara's entitlement to the claimed amount.
  • The Court validated the awards...(Unlock)

Ratio:

  • The Supreme Court highlighted that under the Standard Employment Contract, employers are liable for a seaman's disability benefits if the injury or illness occurs during employment.
  • The petitioners' negligence in failing to provide immediate medical attention contributed to de Lara's health deterioration and subsequent disability.
  • The medical certificate from Dr. Nanette Domingo-Reyes, classifying ...continue reading

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