G.R. No. 222523 - Guerrero vs. Philippine Transmarine Carriers, Inc.

Guerrero was employed by Philippine Transmarine Carriers, Inc. (PTCI), represented by its president Carlos Salinas, on behalf of Celebrity Cruises (CC) as a Casino Dealer aboard the vessel GTS Constellation.
His employment was for a period of six (6) months with a basic monthly salary of US$255.00, and he underwent a pre-employment medical examination wherein he was declared “fit to work as a seaman.”
His job required him to be familiar with various casino games, operating game apparatus, and monitoring patrons for any irregularities.

Guerrero alleged that sometime in January 2012, he sustained a back injury while assisting in the handling of a wheelchair for an elderly passenger during a gastro-intestinal outbreak onboard.
Different versions were later presented:

In his initial Position Paper, Guerrero contended that while pulling a wheelchair to help an elderly passenger disembark (due to an unlevelled platform and steep connecting bridge), a sudden motion caused him to lose balance, resulting in back pain.
In later submissions and statements, he alternatively indicated that the injury occurred during his routine workout at the crew gym, with variations mentioning a fall or hearing a “snap” on his back.

The conflicting narratives raised significant questions regarding the true origin and causation of his alleged injury.

After the incident, Guerrero began experiencing persistent back pain.
He underwent diagnostic tests including a Magnetic Resonance Imaging (MRI) at a facility in the Caribbean, which revealed lumbar spondylosis and disc degeneration with nerve compression.
Upon repatriation to Manila, he was referred for further medical evaluation and treatment at the Manila Doctors Hospital and the Philippine General Hospital (PGH), where he received physical therapy and underwent a major surgery (Transforaminal Lumbar Interbody Fusion of L3-L4 and L4-L5).
Post-surgery, two different medical certificates emerged:

One from Dr. Adrian Catbagan, the company-designated physician, recording his hospital stay and diagnosis as Degenerative Disc Disease and Disc Herniation.
Another from Dr. Cesar H. Garcia, who declared him “UNFIT for further sea service in whatever capacity as a SEAFARER” on the same day of consultation, though this certification was later noted as lacking sufficient supporting diagnostic tests.

Guerrero filed a complaint seeking permanent and total disability benefits, along with claims for compensatory, exemplary, and moral damages, as well as attorney’s fees.
After a series of pre-hearing conferences and submission of position papers before the Labor Arbiter (LA), the LA rendered a Decision on February 28, 2013, finding PTCI and CC solidarily liable to pay Guerrero disability compensation of US$60,000.00, despite acknowledging that the injury occurred during a gym incident.
Respondents, contending that the injury was not work-related and citing evidence (Crew Injury Statement and Personal Injury Illness Statement) that attributed the injury to a gym workout, appealed the LA decision before the National Labor Relations Commission (NLRC).
On July 31, 2013, the NLRC reversed the LA decision, dismissing Guerrero’s complaint for lack of merit on the ground that his injury was not work-related.
Guerrero then assailed the NLRC’s ruling by filing a petition for certiorari before the Court of Appeals (CA), but the CA, in its September 10, 2015 Decision and January 14, 2016 Resolution on motion for reconsideration, affirmed the NLRC decision.
Guerrero subsequently filed the present petition for review on certiorari with the Supreme Court, arguing that he was entitled to disability benefits and alleging grave abuse of discretion in the lower tribunals’ factual findings.

Whether Guerrero’s alleged back injury arose out of, and in the course of, his employment as a Casino Dealer.
Whether the evidence sufficiently established a causal connection between his work duties and the injury.

Whether Guerrero’s inconsistent and conflicting statements regarding the incident (wheelchair incident vs. gym workout) undermine his claim.
Whether the documentary evidence submitted by respondents (Crew Injury Statement and Personal Injury Illness Statement) adequately refuted Guerrero’s version of events.

Whether the Labor Arbiter and the NLRC correctly applied the rules governing compensability of work-related injuries in awarding or denying disability benefits.
Whether the CA erred in affirming the NLRC decision, particularly concerning the evidentiary basis for ruling that the injury was not work-related.

Whether the petition for certiorari raises a proper question for review, given that it essentially calls for a re-examination of the factual determinations made by the NLRC and the CA.
Whether the alleged procedural lapses and new issues raised at the appellate level should be entertained in view of the established principle against raising new issues on appeal.