Title
Lacson vs. RCCL Crew Management Inc., et al.
Case
G.R. No. 270817
Decision Date
Jan 27, 2025
Lacson sought disability benefits after suffering from skin conditions due to work exposure on a vessel. The court evaluated medical evidence and procedural compliance regarding assessments of his condition and entitlements.
A

Case Digest (G.R. No. 165321)

Facts:

  • Employment and Initial Condition
    • On January 30, 2018, Charlonne Keith Lacson (petitioner) entered a six-month Contract of Employment with RCCL Crew Management Inc. (RCCL) on behalf of Royal Caribbean Cruises Ltd.
    • Petitioner, certified fit to work, boarded the vessel Azamara Quest and worked as AZ Commis 2.
    • His duties involved food preparation and kitchen sanitation that exposed him to cleaning materials including sanitizers, bleaches, acids, degreasers, and detergents.
  • Onset and Diagnosis of Illness
    • After few months aboard, petitioner developed skin itching treated initially with steroidal cream but progressed to painful rashes and blisters.
    • Referred to an Italian shore physician/dermatologist, petitioner was diagnosed with allergic dermatitis.
    • Medically repatriated to the Philippines on August 20, 2018, and diagnosed with Contact Dermatitis with Secondary Bacterial Infection by Shiphealth, Inc.
    • Post-employment medical treatment lasted until January 17, 2019.
  • Disputes on Medical Condition and Treatment
    • RCCL requested petitioner to report for redeployment despite visible rashes; advised continuing medication.
    • Petitioner sought further consultations:
      • At Seamen's Hospital dermatologist on February 6, 2019, diagnosed with Hand Dermatitis RIO Allergic Contact Dermatitis and declared unfit for duty.
      • At Casa Medica Inc. on February 20, 2019, diagnosed with Dyshidrotic and Nummular Eczema and declared unfit to work in the kitchen with recommendation to transfer department.
  • Legal Proceedings
    • Petitioner filed complaint for permanent and total disability benefits on March 18, 2019.
    • Respondents contended petitioner had pre-existing allergies to environment, chemicals, foods, or drugs as declared pre-employment.
    • Respondents presented medical evidence showing improvement and eventual resolution of petitioner’s condition after treatment by company-designated physician, Shiphealth.
  • Decisions of Lower Bodies
    • Labor Arbiter dismissed complaint for failure to comply with third-doctor rule; Shiphealth findings final and binding.
    • NLRC affirmed dismissal of complaint.
    • Court of Appeals upheld lower rulings, found no permanent total disability or basis for claim; accepted Shiphealth’s final report dated January 17, 2019 that petitioner was fit for duty.
  • Petitioner’s Arguments on Appeal
    • Company-designated physician’s findings are not binding if unsupported by medical records.
    • The final report was not disclosed timely, lacked named physician, specialty, and was indefinite regarding fitness to work.
  • Respondents’ Rejoinder
    • The issue is factual; petitioner’s illness is pre-existing and not compensable.
    • Petitioner admitted prior allergies specifically to latex and nickel.
    • Petitioner was eventually cleared fit for duty after treatment.
    • Company-designated physician’s assessments are final unless challenged through third doctor.

Issues:

  • Is petitioner entitled to permanent and total disability benefits?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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