Title
HFS Philippines, Inc. vs. Pilar
Case
G.R. No. 168716
Decision Date
Apr 16, 2009
A seafarer awarded disability compensation for work-related depression and gastric ulcer based on social justice principles and independent medical findings.
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Case Digest (G.R. No. 168716)

Facts:

  • HFS Philippines, Inc., Ruben T. Del Rosario, and IUM Shipmanagement AS are the petitioners against Ronaldo R. Pilar, the respondent.
  • Pilar was hired as a crew member on the M/V Hual Triumph on October 4, 2001, under a nine-month contract with a monthly salary of US $981, overtime pay, and vacation leave.
  • He boarded the vessel on October 27, 2001, but by March 2002, he experienced severe health issues, including loss of appetite, nausea, vomiting, and nervousness.
  • Pilar was hospitalized in Japan, diagnosed with depression and a gastric ulcer, and deemed unfit for work, leading to his repatriation on April 3, 2002.
  • Upon returning to Manila, Dr. Nicomedes G. Cruz confirmed his diagnosis of major depression and prescribed continuous medical treatment.
  • Pilar was declared fit to work on September 19, 2003, but sought additional opinions indicating ongoing health issues.
  • On November 27, 2002, he filed a complaint with the NLRC for underpayment of disability and medical benefits, as well as moral and exemplary damages.
  • The case was referred to the NCMB due to Pilar's union membership, where he claimed his health issues arose from an incident on March 9, 2002.
  • The petitioners argued that Pilar's depression was not accident-related, limiting his entitlement to 120-day sick pay under the CBA.
  • The NCMB ruled in favor of Pilar, stating his psychological condition was compensable, which was affirmed by the Court of Appeals.
  • The petitioners subsequently filed a petition for certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, affirming the decisions of the Court of Appeals and the NCMB.
  • While Pilar was not entitled to disability compensation under Article 12 of the CBA, he was entitled t...(Unlock)

Ratio:

  • The Supreme Court highlighted that a Collective Bargaining Agreement (CBA) is binding and must be adhered to in good faith.
  • Pilar's illness occurred during his employment, qualifying him for sick pay as per the CBA and employment contract.
  • Article 12 of the C...continue reading

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