Case Digest (G.R. No. 107131)
Facts:
NFD International Manning Agents, Inc. v. National Labor Relations Commission (Second Division) and Romel Bearneza, G.R. No. 107131, March 13, 1997, Supreme Court First Division, Hermosísima, Jr., J., writing for the Court.Petitioner NFD International Manning Agents, Inc. employed private respondent Romel Bearneza as a wiper on board M/S Wilnina under a ten-month contract commencing February 15, 1985 with a monthly salary of US$413. On November 8, 1985, while aboard the vessel in Japan, Bearneza was mauled by unidentified persons and was diagnosed with contusions and suspected epilepsy; he was repatriated and treated at St. Luke’s Hospital where an attending physician recorded epilepsy and later (February 3, 1986) declared him fit to resume work.
Between September 25, 1986 and January 1, 1987 Bearneza was confined for 98 days at Western Visayas Medical Center and was diagnosed with Schizophreniform Disorder, which his treating psychiatrist later certified as constituting permanent total disability. He claimed contractual insurance benefits of US$30,000 under his crew contract. Documentary proof and medical certificates were submitted by both parties at administrative proceedings.
The Philippine Overseas Employment Agency (POEA) considered only whether Bearneza was entitled to permanent total disability benefits and ruled against him, finding that the schizophrenia was diagnosed after he was declared fit and after the contract period and that epilepsy does not cause Schizophreniform Disorder. Aggrieved, Bearneza appealed to the National Labor Relations Commission (NLRC), Second Division (Commissioners Rustico L. Diokno, Edna Bonto-Perez and Domingo H. Zapanta). The NLRC reviewed the same factual record, found that the February 1986 fitness finding was limited and inconclusive (no mental exam), accepted medical opinion linking epilepsy/psychiatric problems and head trauma, and reversed the POEA by awarding the US$30,000 permanent total disability benefit. The NLRC relied in part on medical literature and cited Abaya Jr. v. ECC and Orlino v. ECC in defining permanent total disability.
Petitioner filed a petition for certiorari with the Supreme ...(Subscriber-Only)
Issues:
- Did the NLRC commit grave abuse of discretion amounting to lack or excess of jurisdiction in granting permanent total disability benefits to Romel Bearneza?
- On the merits, was Bearneza entitled to permanent total disability benefits under his employment contract because his Schizophreniform Disorder was causally connected to injuries sust...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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