G.R. No. 165691 - Barbers vs. Commission on Elections

Nelson A. Go was employed by OSM Maritime Services, Inc. as an oiler/motorman since 2009, with his last contract signed on March 31, 2015 for a nine (9)–month period at a basic salary of US$709.00.
His employment was additionally covered by a Collective Bargaining Agreement (CBA), which later became central to the calculation of disability benefits.

On December 16, 2015, while onboard the vessel M/V Trinity Arrow, petitioner experienced symptoms such as dizziness, vomiting, chest pain, shortness of breath, and elevated blood pressure (160/90).
Admitted in a Singapore hospital, he was diagnosed with sub-acute myocardial infarction with new onset hypertension.
After repatriation on December 22, 2015, he was examined by the company-designated physician, Dr. Nicomedes Cruz, who in a certificate dated January 20, 2016 noted Meniere’s Disease as part of the diagnosis, while simultaneously stating that the condition was not work-related.

Further assessments led Dr. Cruz on March 28, 2016 to issue a certificate diagnosing petitioner with hypertension, Meniere’s Disease, and myofascial spasm, while still certifying him fit to resume sea duties.
On June 8, 2016, during his Pre-Employment Medical Examination (PEME) at the Maritime Clinic for International Seafarers (MCIS), petitioner was found unfit for sea duty due to his Meniere’s Disease.
An email from MCIS physician Dr. Olivia Salve T. Sales confirmed that Meniere’s Disease, characterized as a disease of unknown cause affecting the ear’s membranous labyrinth and producing symptoms like progressive deafness, tinnitus, and vertigo, rendered petitioner unfit for seafaring.

On July 26, 2016, petitioner consulted his own doctor, Dr. Radentor Viernes, who declared the disease work-related and work-aggravated, citing exposure to engine noise, heat, and chemicals as contributory factors, and stating that petitioner was no longer fit for any capacity as a seaman.
On September 9, 2016, petitioner filed his complaint seeking permanent and total disability benefits amounting to US$90,000.00 per the parties’ CBA, along with claims for moral and exemplary damages and attorney’s fees.

On December 27, 2016, the Labor Arbiter (LA) ruled in favor of petitioner by declaring his illness work-related but granted only US$3,702.60, reasoning that he was not permanently and totally incapacitated for full benefit entitlement.
Petitioner, dissatisfied with the LA’s partial award, elevated the issue to the National Labor Relations Commission (NLRC).
In its February 27, 2017 Decision, the NLRC denied petitioner’s appeal on the basis that his Meniere’s Disease was not shown to be work-related, heavily relying on the fact that petitioner’s evidence—particularly the non-sustained medical examination of Dr. Viernes—failed to establish causation.

On January 5, 2018, the Court of Appeals (CA) reversed the NLRC’s ruling, declaring petitioner’s disease as work-related and awarding him full permanent disability benefits of US$90,000.00 plus 10% attorney’s fees.
A subsequent Motion for Reconsideration by the petitioners was denied on March 14, 2018, prompting petitioner to file a Petition for Review on Certiorari before the Supreme Court.
In his filings, petitioner challenged the CA’s decision on multiple grounds, including alleged grave abuse of discretion by the NLRC and issues relating both to the disability grading and the award of attorney’s fees.

Whether or not the CA committed grave abuse of discretion by holding that the NLRC overstepped its jurisdiction when it ruled that petitioner’s illness was not work-related, despite the issue being already settled by the Labor Arbiter’s final finding.
Whether or not the CA committed grave abuse of discretion in awarding petitioner total and permanent disability benefits, given that his condition allegedly does not merit a Grade 1 disability and there was no sufficient showing of permanent unfitness for sea duties.
Whether or not the CA committed grave abuse of discretion in affirming the award of attorney’s fees.