Case Digest (G.R. No. 204101)
Facts:
The Late Alberto B. Javier, as Substituted by His Surviving Wife, Ma. Theresa M. Javier, and Children, Kladine M. Javier, Christie M. Javier, Jalyn M. Javier, Candy Grace M. Javier and Glizelda M. Javier v. Philippine Transmarine Carriers, Inc. and/or Northern Marine Management, Ltd., G.R. No. 204101, July 02, 2014, Supreme Court Second Division, Brion, J., writing for the Court.Petitioner heirs (substituting the deceased Alberto B. Javier) sued respondents Philippine Transmarine Carriers, Inc. (PTCI) and Northern Marine Management, Ltd. (collectively, the respondents) for benefits arising from Alberto’s illness while on board the vessel MT Neptune Glory. Alberto was hired on March 3, 2003 as pumpman under his twentieth contract with the respondents and underwent a Pre-employment Medical Examination (PEME) and was declared fit by the company-designated physician.
On November 10, 2003 Alberto experienced severe headache, dizziness and vomiting and was later hospitalized in Galveston, Texas where he was diagnosed with hypertension and repatriated to the Philippines on November 23, 2003. He received further treatment in Manila and on March 30, 2004 underwent coronary artery bypass surgery. A private cardiologist later assessed him as impediment grade 1 and unfit to resume seafaring duties.
Alberto filed a complaint before the Labor Arbiter (LA) for disability benefits, sickness allowance, reimbursement of medical expenses, damages and attorney’s fees under the 2000 POEA Standard Employment Contract (POEA-SEC). In a May 31, 2005 decision, the LA awarded a total of US$68,886.40 (US$60,000 permanent total disability; US$2,624 sickness allowance for 120 days; and 10% attorneys’ fees) but denied reimbursement of medical expenses and damages.
On March 10, 2006 the National Labor Relations Commission (NLRC) affirmed with modification: it concluded Alberto’s illness was work-related and found that respondents had paid P144,318.03 (sickness allowance) and P1,928,841.27 (medical expenses) as evidenced by an April 12, 2004 certification; the NLRC ordered deduction of those amounts from the peso equivalent of the LA’s monetary award. Alberto died on November 1, 2005; his heirs substituted him and sought reconsideration, which the NLRC denied.
The heirs filed a petition for certiorari with the Court of Appeals (CA). In its May 31, 2012 decision (and October 23, 2012 resolution) the CA affirmed the NLRC: it declined the heirs’ claim for reimbursement of medical expenses (because the LA had denied it and that denial became final), upheld the deduction for sickness allowance based on the April 12, 2004 certification, and rejected a claim for death benefits because Alberto died after his contract had already terminated.
The heirs then filed a petition for review on certiorari under Rule 45 of the Rules of Court ...(Subscriber-Only)
Issues:
- Did the Court of Appeals correctly determine, under Rule 65 review as characterized for Rule 45 purposes, whether the NLRC committed grave abuse of discretion in ordering deductions from the LA’s monetary award (procedural question of the scope of review)?
- Are medical expenses, sickness allowance, and disability benefits distinct and cumulative obligations under the POEA-SEC, and if so, may employer-paid medical expenses and sickness allowance be deducted from a monetary award for disability benefits?
- Were the respondents entitled to deduct the sickness allowance and the medical...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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