Case Digest (G.R. No. 182604) Core Legal Reasoning Model
Facts:
Rodelio R. Onia filed a petition for review on certiorari against Leonis Navigation Company, Inc. (LNCI) and World Maritime Co. Ltd., alongside several individuals affiliated with LNCI. The case arose from Onia's claim for total and permanent disability benefits and damages following a medical emergency during his employment as an oiler on board the MV Navios Koyo, which started on February 13, 2014. On May 20, 2016, while in transit from China to Colombia, Onia experienced symptoms indicative of a stroke, subsequently diagnosed upon repatriation with cerebrovascular infarct, hypertensive cardiovascular disease, and diabetes mellitus. Onia contended that his condition was work-related and sought compensation after being denied medical assistance by LNCI following his illness. The Labor Arbiter originally ruled in favor of Onia, granting him various compensatory awards. However, this decision was reversed by the National Labor Relations Commission (NLRC), which ruled that On
Case Digest (G.R. No. 182604) Expanded Legal Reasoning Model
Facts:
- Parties and Employment Relationship
- Petitioner Rodelio R. Onia, a Filipino seafarer employed as an oiler.
- Respondents include Leonis Navigation Company, Inc. (LNCI), its foreign principal World Maritime Co. Ltd. (World Maritime), and various board members and corporate officers (e.g., Capt. Hernani P. Feusca, Felix Andrada, Ricardo Nolledo, Ryo Matsunaga, Takashi Uto, Valeriano R. Del Rosario, Mary Jean Madrenero, and Jennifer E. Cerrada).
- LNCI is engaged in recruiting and deploying Filipino seafarers for ocean-going vessels, operating under the employment contract and the 2010 POEA Standard Employment Contract.
- Pre-Employment Medical Examination and Deployment
- Prior to deployment, petitioner underwent a Pre-Employment Medical Examination (PEME) on August 18, 2015, performed by LNCI’s company-accredited physician, Dr. Peter O. Dator.
- Despite declaring petitioner "fit for sea duty," Dr. Dator prescribed maintenance medicines for the management of his hypertensive cardiovascular disease and diabetes mellitus, thereby alerting LNCI to his pre-existing medical conditions.
- Petitioner subsequently embarked on the MV Navios Koyo on November 2, 2015 for a nine‑month deployment that had officially commenced on February 13, 2014.
- Onset of Illness and Medical Treatment
- On May 20, 2016, while en route from China to Colombia, petitioner experienced sudden onset of symptoms including dizziness, blurred vision, numbness on the right side, and slurred speech, consistent with a stroke.
- Immediate onboard treatment was administered, followed by further medical attention in Brazil where he was confined for two weeks starting May 24, 2016.
- Petitioner was repatriated on June 13, 2016 and admitted to Manila Doctors Hospital on June 17, 2016.
- Laboratory tests and examinations led to a diagnosis of "Cerebrovascular infarct, Left Pons, Hypertensive Cardiovascular Disease and Diabetes Mellitus."
- After discharge on June 22, 2016, petitioner was advised to continue with follow-up checkups; however, when seeking further assistance from LNCI’s designated medical service provider, he was informed that additional medical expenses were to be borne by him.
- Filing of the Claim and Proceedings Before Lower Tribunals
- Dissatisfied with the lack of medical assistance and financial support, petitioner consulted his personal physicians (Dr. Petrarch B. Bravo and Dr. Carlos L. Chua) who subsequently declared him permanently and totally disabled.
- Petitioner filed a complaint before the National Labor Relations Commission (NLRC) for total and permanent disability benefits, moral and exemplary damages, and attorney’s fees.
- The Labor Arbiter (LA) rendered a Decision on June 30, 2017, awarding petitioner disability benefits of US$60,000.00, moral and exemplary damages of P100,000.00, and attorney’s fees (10% of the total award).
- The NLRC reversed the LA’s Decision on September 29, 2017, dismissing the claim on the ground that petitioner’s illness was not work-related and that he had concealed his pre‑existing conditions during his PEME.
- On appeal, the Court of Appeals (CA) affirmed the NLRC ruling in its Decision on September 30, 2020 and further denied petitioner’s motion for reconsideration on June 11, 2021.
Issues:
- Whether the CA erred in holding that petitioner was not entitled to disability benefits, moral and exemplary damages, and attorney’s fees.
- Whether petitioner’s alleged concealment of his pre‑existing conditions (hypertension and diabetes mellitus) during his PEME disqualifies him from receiving benefits.
- Whether petitioner’s illness, diagnosed as a cerebrovascular infarct with accompanying hypertensive cardiovascular disease and diabetes mellitus, is work-related and compensable under the provisions of the 2010 POEA‑SEC.
- Whether the failure of the company-designated physician to furnish a final and definite disability assessment within the prescribed period renders petitioner’s disability as total and permanent by operation of law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)