Case Digest (G.R. No. 222311) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 222311, decided on February 10, 2021 under the 1987 Constitution, petitioner V People Manpower Phils., Inc. (V Manpower), acting for its principal Cape Papua New Guinea Ltd. (Cape PNG), engaged respondent Dominador C. Buquid on January 17, 2012 as Deck Crew/Rigger for the KUMUL Marine Terminal Rejuvenation Works in Papua New Guinea. Buquid passed a Pre-Employment Medical Examination and was declared fit to work. On March 27, 2012 he underwent an appendectomy and colostomy after persistent abdominal pain. He was repatriated on April 8, admitted at Asian Hospital from April 9 to 12, and on May 9, 2012 was diagnosed with Stage 3 Colon Cancer. Oncologist Dr. Jhade Lotus P. Peneyra issued medical abstracts stating Buquid’s illness was occupation-related and that he was permanently unfit for sea duties. Buquid claimed permanent and total disability benefits under the POEA Standard Employment Contract (POEA-SEC), but V Manpower denied liability, insisting he was a land-base Case Digest (G.R. No. 222311) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Engagement and Deployment
- In January 2012, V People Manpower Phils., Inc. (V Manpower) hired Dominador C. Buquid for and on behalf of Cape Papua New Guinea Ltd. (Cape PNG) as a Deck Crew/Rigger under a six-month contract (January 17 to July 17, 2012) for the KUMUL Marine Terminal Rejuvenation Works in Papua New Guinea.
- Prior to departure, Dominador passed a Pre-employment Medical Examination (PEME) and was declared “fit to work” by the company-designated physician.
- Work Conditions and Alleged Exposures
- On board the offshore platform, Dominador performed tasks such as cleaning the platform, installing fenders, signaling crane operations, checking for pipeline leakages, painting and chipping rust, constructing scaffolds, and maintaining rigging gears.
- He worked at least twelve hours daily under harsh sea conditions, exposed to fumes, fuel oils, gases, dust, and other chemicals, and subsisted on a high-carbohydrate, high-fat diet.
- Medical Events and Diagnosis
- On March 26, 2012, Dominador experienced persistent stomach pains; the next day he underwent an appendectomy and colostomy after a mass was discovered in his colon. He was repatriated on April 8 and admitted to Asian Hospital on April 9.
- After follow-up examinations, he was diagnosed on May 9, 2012 with Stage 3 Adenocarcinoma Sigmoid (colon cancer).
- Medical Opinions and Initial Claim
- Oncologist Dr. Jhade Lotus P. Peneyra issued abstracts stating Dominador’s cancer was occupation-related/aggravated and that he was permanently unfit for sea duties, citing his 22-year seafaring history and exposure to carcinogens and poor onboard diet.
- Dominador filed for permanent and total disability benefits under the POEA Standard Employment Contract (POEA-SEC), but his claim was denied by petitioners.
- Labor Proceedings
- National Labor Relations Commission (NLRC) Complaint
- Labor Arbiter (LA) ruled Dominador a seafarer and awarded US$60,000 permanent total disability benefits plus US$6,000 attorney’s fees.
- NLRC reversed the LA, classifying him as a land-based employee and awarding only US$598.08 as final pay.
- Court of Appeals (CA)
- The CA granted Dominador’s Petition for Certiorari, reinstating the LA’s award of US$60,000 and attorney’s fees.
- V Manpower and Cape PNG moved for reconsideration, which the CA denied.
- Supreme Court Review
- V Manpower and Cape PNG filed a Petition for Review on Certiorari raising errors of law and fact in the CA decision.
Issues:
- Whether the CA erred in reversing the NLRC decision and awarding permanent and total disability benefits under the POEA-SEC when Dominador was never employed as a seafarer and his colon cancer was not shown to be work-related.
- Whether the CA committed reversible error in awarding attorney’s fees in the absence of any finding of bad faith or malice on the part of petitioners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)