G.R. No. 211301 - Park Developers, Inc. vs. Daclan

Petitioner, Virgilio S. Suelo, Jr., was hired by respondent MST Marine Services (Phils.), Inc. on May 10, 2016, as Second Engineer under a six‑month contract.
His compensation package included a basic monthly salary of $1,551.00, along with overtime pay of $1,155.00 and vacation leave pay of $466.00, among other benefits.
He embarked on board the vessel "Janesia Asphalt V" on May 28, 2016, thereby commencing his maritime duties.

On October 29, 2016, while at sea, petitioner experienced severe health issues including a severe headache, slurring of speech, and neck pain, in addition to a history of loss of consciousness.
He was admitted at Singapore General Hospital where he was diagnosed with uncontrolled hypertension and his X-ray revealed degenerative changes at the C5-6 and C6-7 levels.
Following the diagnosis, he was declared unfit for all marine duties and was signed off on medical grounds in Singapore.

Upon his return to the Philippines on November 4, 2016, petitioner traveled immediately to his hometown in Iloilo.
On November 7, 2016, he reported to the respondent’s branch office in Iloilo to address concerns regarding his medical condition.
He alleged that the respondent denied him reporting to its Manila office and refused to refer him to a company-designated physician; instead, he contended that the respondent instructed him to undergo medical treatment subject to reimbursement.
Petitioner further claimed that, following his submission for cost reimbursement of his medical treatment, the respondent denied his claim.

Petitioner filed a complaint before the National Conciliation and Mediation Board (NCMB), seeking permanent and total disability benefits, damages, and attorney’s fees.
Respondent argued that the petitioner had refused to undergo treatment with the company-designated physician, thereby forfeiting claims for disability benefits and sick wages.
The respondent also maintained that without any evidence of bad faith on its part, petitioner was not entitled to sickness allowance, damages, or attorney’s fees.

In the VA Decision dated February 18, 2019, petitioner’s claim was denied.
The VA rejected petitioner’s allegation that the company instructed him to seek treatment on a reimbursement basis, noting that his medical abstract indicated he sought treatment approximately a year after disembarkation.
Additionally, the VA held that petitioner failed to submit evidence of his medical expenses, while respondent was substantiated by evidence that petitioner's condition had led him to refuse the company-designated physician.

Petitioner, aggrieved by the VA ruling, filed a motion for reconsideration, which was ultimately denied in a June 28, 2019 Resolution.
On July 22, 2019, petitioner sought a twenty (20)-day extension to file a petition for review before the CA.
On August 9, 2019, he filed a Rule 43 Petition for review, although the CA Resolution dated September 3, 2019 dismissed it on two procedural grounds:

The petition was filed two days late.
The affidavit of service was inaccurate, as it erroneously stated that service was effected personally rather than by registered mail.

Petitioner subsequently filed a motion for reconsideration of the CA dismissal, which was denied by the CA Resolution dated March 6, 2020, affirming that the right to appeal is a statutory privilege to be exercised in strict compliance with the Rules of Court.

Whether the Court of Appeals erred in dismissing the Rule 43 Petition on procedural grounds, specifically with regard to:

The timeliness of filing the petition given the extension period under the Rules of Court; and
The inaccuracy in the affidavit of service concerning the mode of service of the petition.

Whether the procedural errors cited — namely, the filing deadline and the nature of service — should warrant an outright dismissal of the petition for review.

The correct interpretation and application of Section 4, Rule 43 of the Rules of Court and Article 276 of the Labor Code regarding:

The time within which an aggrieved party may file a motion for reconsideration; and
The subsequent allowable period for filing a petition for review.