Case Digest (G.R. No. 230735)
Facts:
Paglinawan v. Dohle Philman Agency, Inc., G.R. No. 230735, April 04, 2022, Supreme Court Second Division, Hernando, J., writing for the Court.Petitioner Edgardo M. Paglinawan sued respondents Dohle Philman Agency, Inc., Dohle‑IOM (Limited) and Manolo T. Gacutan for recovery of permanent and total disability benefits, sickness allowance, and attorney’s fees after being medically repatriated from the vessel MN Tamina. Petitioner signed an employment contract on March 19, 2013 that was approved by the POEA the same day.
While aboard, petitioner alleged exposure to dust, chemicals, strenuous work, extreme temperature changes, harsh weather and other stressors. In July–August 2013 he suffered bloody stools and was hospitalized in Mexico City; biopsy showed diffuse lymphoid hyperplasia. He was repatriated in mid‑August 2013 and treated by the company‑designated physicians at Metropolitan Medical Center, where he underwent tests and laparoscopic cholecystectomy and was diagnosed with ulcerative colitis, iron‑deficiency anemia and cholelithiasis. The company‑designated physician’s medical report dated September 27, 2013 stated these conditions were not work‑related and declared him unfit for sea duties for approximately three months. Respondents stopped further treatment payments and paid sickness allowance.
Petitioner sought payment of disability benefits, later procured a medical certification from Dr. Rommel F. Galvez opining he was unfit to work, and filed a complaint on January 7, 2014. The Labor Arbiter (LA), in a December 29, 2014 Decision, found petitioner’s ulcerative colitis to be work‑aggravated and ordered respondents to pay US$60,000.00 as permanent total disability compensation and US$6,000.00 as attorney’s fees. Respondents appealed.
The National Labor Relations Commission (NLRC), in a March 3, 2015 Decision, reversed and set aside the LA, dismissing the complaint for lack of merit; the NLRC held there was no reasonable causal connection between work and petitioner’s illness and discounted petitioner’s doctor’s certificate as self‑serving. The NLRC denied reconsideration in a May 25, 2015 Resolution. Petitioner filed a petition for certiorari with the Court of Appeals (CA). The CA, in a December 14, 2016 Decision, dismissed the petition and affirmed the NLRC, holding that the disputable presumption of work‑relatedness was succes...(Subscriber-Only)
Issues:
- Was petitioner’s claim for permanent and total disability prematurely filed?
- Was petitioner entitled to permanent and total disability benefits because his ulcerative colitis was work‑related or work...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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