Case Digest (G.R. No. 176217)
Facts:
Magsaysay Maritime Services and Princess Cruise Lines, Ltd., G.R. No. 195518, March 20, 2013, Supreme Court Third Division, Mendoza, J., wrote for the Court. Earlwin Meinrad Antero F. Laurel (respondent) was employed by Princess Cruise Lines, Ltd. through manning agent Magsaysay Maritime Services as second pastryman aboard M/V Star Princess under a POEA‑approved employment contract (the 2000 POEA-Standard Employment Contract or POEA‑SEC) executed in June 2004; he underwent pre‑employment medical clearance and was deployed in August 2004.During the voyage Laurel developed fever and cough; he disembarked in Florida on April 3, 2005 and was repatriated to the Philippines on April 7, 2005. On April 8–11, 2005 he was treated at Metropolitan Hospital, diagnosed with upper respiratory tract infection and hyperthyroidism, and a hospital report indicated the hyperthyroidism was “not work‑related.” On April 25, 2005 the company medical facility cleared his pulmonary condition but advised consultation with an internist for the thyroid condition. Thereafter Laurel consulted Dr. Ramon Caceres; by January 21, 2006 he was treated for Euthyroid Graves Disease and, on August 12, 2006, was further diagnosed with Graves Disease (Stage 1B diffuse goiter) with recurrent periodic paralysis and assessed as equivalent to Grade 1 impediment.
On August 3, 2006 Laurel filed a complaint before the National Labor Relations Commission (NLRC) for medical reimbursement, sickness allowance, permanent disability benefits, damages and attorneys’ fees. The Labor Arbiter dismissed the complaint on February 1, 2007, ruling the hyperthyroidism was not work‑related and citing the POEA‑SEC scheme that employer liability attaches only to work‑related illnesses established by the company‑designated physician. The NLRC reversed in a September 17, 2007 decision and awarded disability benefits of US$60,000 (to be paid by petitioners), holding that illnesses occurring during employment are presumptively work‑related under the POEA‑SEC and that the employer failed to rebut that presumption. The petitioners sought certiorari relief with the Court of Appeals (CA), which dismissed the petition in an August 6, 2010 Decision and den...(Subscriber-Only)
Issues:
- In a Rule 45 petition, may the Court revisit and overturn the factual findings of the NLRC and the Court of Appeals in this labor case?
- Is respondent Laurel’s hyperthyroidism compensable under the 2000 POEA‑SEC as a work‑related illness contracted during the term of his employment?
- Does the POEA‑SEC’s presumption of compensability for illnesses not listed in Section 32 operate in favor of Laurel, and if so, did petitioners overcome that presumption?
- Is the determination of the company‑designated physician conclusive and bind...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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