Case Digest (G.R. No. 270817)
Facts:
Charlonne Keith Lacson v. RCCL Crew Management Inc., Royal Caribbean Cruises Ltd., and Gerardo Antonio Borromeo, G.R. No. 270817, January 27, 2025, the Supreme Court First Division, Hernando, J., writing for the Court.Petitioner Charlonne Keith Lacson contracted with RCCL Crew Management Inc. for the principal Royal Caribbean Cruises Ltd. on January 30, 2018 for six months and boarded the vessel Azamara Quest as AZ Commis 2 after a fit-to-work certification. His duties involved food preparation and kitchen sanitation that exposed him to sanitizers, bleaches, acids, degreasers and detergents. After several months he developed pruritic lesions; initial shipboard treatment included steroidal cream and later referral to an Italian dermatologist who diagnosed allergic dermatitis. He was medically repatriated on August 20, 2018.
On August 24, 2018 the company-designated physician, Shiphealth, Inc., diagnosed Contact Dermatitis with Secondary Bacterial Infection and provided ongoing treatment through January 17, 2019. Despite intermittent improvement documented in Shiphealth records (including intralesional steroid injections in December 2018–January 2019), petitioner continued to seek private care. A Seamen’s Hospital medical certificate dated February 6, 2019 declared him "UNFIT for duty"; on February 20, 2019 Dr. Miguel Maralit diagnosed Dyshidrotic Eczema and Nummular Eczema and recommended transfer from kitchen duties. Petitioner filed a complaint for permanent and total disability benefits on March 18, 2019.
Respondents relied on pre-employment records showing petitioner answered "Yes" to allergies but specified latex and nickel, and on Shiphealth records showing improvement and a Final Report dated January 17, 2019 stating "Final diagnosis: nummular eczema, resolved" and that petitioner was "cleared by Dermatology service." A Crew Fit for Duty Notice dated January 24, 2019 also appears in the file. Petitioner alleged he only saw Shiphealth’s Final Report in respondents’ position paper and contended the Final Report did not identify the examining doctor or duly furnish the assessment to him.
The Labor Arbiter dismissed petitioner’s complaint on October 17, 2019 for failure to comply with the third‑doctor rule and for lack of a final and definite assessment by a third physician. The NLRC, Fourth Division, affirmed on February 26, 2021. The Court of Appeals dismissed petitioner’s petition for certiorari on April 14, 2023 and denied reconsiderati...(Pro-only)
Issues:
- May the Supreme Court review the factual findings of the lower tribunals in this Rule 45 petition?
- Is petitioner entitled to permanent and total disability benefits under the POEA Standard Employment Contract and app...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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