G.R. No. 249567 - Hartman Crew Philippines vs. Acabado

Randy V. Acabado was employed as a seafarer by Hartman Crew Philippines (formerly Associated Ship Management Services, Inc.) as manning agent for Sea Giant Shipmanagement Ltd.
He was hired as a Wiper with a basic monthly salary of US$462 and began work on board M/T Gaschem Rhone on March 16, 2015.
On August 23, 2015, while transferring a lube oil pump spare part, Acabado injured his knees and subsequently slipped and fell on the following day.
On August 25, 2015, after experiencing “locking” on his right knee, he reported his condition to the Second Officer, who prepared an Accident Report indicating a slight twist of the right knee.

Acabado underwent initial therapy on August 27, 2015, after being examined by an Indonesian doctor.
Upon the vessel’s arrival in Singapore on August 29, 2015, an X-ray revealed a “meniscus tear” on his right knee, prompting further examination at Mt. Elizabeth Hospital by Dr. Jeffrey Goh who recommended repatriation and surgery.
After repatriation to the Philippines on August 29, 2015, Acabado was referred to Dr. Natalio Alegre II at Hartman’s main office.
Although Acabado requested that his left knee be included in the examination, Sea Giant denied the request.
On September 16, 2015, Acabado underwent surgery on his right knee at the Chinese General Hospital.
Post-surgery, he attended several physical therapy sessions until Dr. Alegre discontinued treatment on April 4, 2016.
Additional consultations took place at the Philippine Orthopedic Center and Ospital ng Makati in January 2016, where diagnoses such as “medial meniscus tear” on both knees were made, including a later assessment citing “S/p meniscectomy, right medial meniscus.”

Acabado filed a complaint for disability benefits and other money claims against Hartman Crew Philippines, Sea Giant Shipmanagement, and Alberto L. Gomez.
The company-designated physician, Dr. Alegre, issued progress reports (including the 1st, 13th, and 20th Progress Reports) which showed an initial disability grading of Grade 10 but did not provide a final and definitive medical assessment.
The Labor Arbiter issued a Decision on March 2, 2017, awarding Acabado US$60,000.00 as permanent total disability benefits, along with attorney’s fees equivalent to 10% of the award.
Petitioners (Hartman Crew Philippines and Sea Giant Shipmanagement) and Gomez elevated the case to the NLRC, which on May 30, 2017, reduced the award to US$10,075.00 plus attorney’s fees, but later denied Acabado’s Motion for Reconsideration on July 27, 2017.
On June 21, 2019, the Court of Appeals (CA) set aside the NLRC decision and reinstated, with modification, the Labor Arbiter’s original ruling by ordering payment of US$60,000.00 as disability benefits and US$6,000.00 as attorney’s fees, subject to interest.
Petitioners challenged the CA ruling, arguing procedural irregularities regarding the assessment by the company-designated physician, the credibility of independent physicians’ opinions, and the legal basis for awarding attorney’s fees.

Whether the CA correctly held petitioners liable to pay respondent permanent total disability benefits and attorney’s fees.

Did the CA err in determining that the failure of the company-designated physician to issue a final and definitive disability assessment within the prescribed period automatically renders the seafarer permanently and totally disabled?

Whether the company-designated physician’s “interim” or suggestive assessment (Grade 10 rating) suffices to determine the seafarer’s disability status and entitlement to benefits.
Whether the independent physicians’ opinions, which differed from the company-designated physician’s non-final evaluation, should affect the claim for disability benefits.
Whether the award of attorney’s fees is legally justified under the circumstances and pursuant to Article 2208 of the Civil Code.