G.R. No. 239257 - Ventis Maritime Corp. vs. Cayabyab

Ventis Maritime Corporation (VMC), a local manning agency, and its foreign principal, St. Paul Maritime Corporation (SPMC), are the petitioners.
Joseph B. Cayabyab is the respondent, employed as a wiper on board the vessel “M/V Dover Highway” under a nine‐month contract.
Cayabyab was hired on July 9, 2012, with a basic monthly salary of USD422.00.

Prior to deployment, Cayabyab underwent a Pre-Employment Medical Examination (PEME) and was declared fit for sea duty.
During his employment, he reportedly skipped meals in order to assist other crew members, which later led to health issues.
He exhibited erratic sleeping patterns and complained of poor nutrition that might have contributed to his deteriorating mental health.

He started talking to himself and reciting Bible verses unexpectedly.
An episode of paranoia, hysteria, and violence occurred when he believed someone was about to kill him, necessitating restraint by fellow crew members.

On February 25, 2013, the vessel’s master reported his bizarre behavior to VMC after Cayabyab attempted to contact his family.
Upon arrival at the Port of Italy, he was confined in a psychiatric clinic for three days, where he was initially diagnosed with “Occupational Stress Disorder” and “ACUTE PSYC[H]OSIS.”
After repatriation to the Philippines:

VMC referred him to the company-designated physician who later endorsed him to a psychiatrist at the Philippine General Hospital.
The psychiatrist prescribed medication for schizophrenia and, during a follow-up visit on March 18, 2013, diagnosed him with a “Brief Psychotic Episode.”
Subsequent medical evaluations showed improvement, with a declaration of being “symptom-free” despite discontinuation of medication on April 17, 2013.

The company-designated physician continued to monitor his condition with several follow-up examinations (April 17, May 15, May 31, June 14, and June 28, 2013), culminating in a July 12, 2013 assessment noting complaints of a recurrent occipital headache, insomnia, limited verbal output, and recurrence of auditory hallucinations.
On July 15, 2013, the company-designated physician issued a Grade 6 Disability Assessment.

Dissatisfied with the partial disability assessment, Cayabyab filed a Complaint for total and permanent disability benefits on July 29, 2013.
At the Labor Arbiter level, a decision dated February 21, 2014 awarded him total and permanent disability benefits, directing the petitioners to pay US$60,000.00 jointly and severally.
The petitioners appealed the Labor Arbiter’s decision, leading the NLRC to render a decision on October 31, 2014:

The NLRC partially modified the Labor Arbiter’s award, holding VMC liable to pay disability benefits based on a Grade 6 rating under the Amended POEA-SEC.
Cayabyab’s subsequent Motion for Reconsideration before the NLRC was denied.

Cayabyab elevated the case to the Court of Appeals (CA) via a Petition for Certiorari, contesting the basis of the disability benefit award.
The CA, in its September 25, 2017 decision, affirmed the NLRC’s finding by giving credence to the company-designated physician’s assessment and applying a purported Collective Bargaining Agreement (CBA).
Petitioners later filed a Motion for Partial Reconsideration (MR) questioning:

The applicability of the CBA in light of the fact that it allegedly expired on December 31, 2009, and
The imposition of six percent (6%) legal interest per annum on the judgment award.

A letter from the union indicated that the provisions of the CBA on disability benefits were still in effect, and
The six percent interest was proper pursuant to established jurisprudence.

While the petition before the Supreme Court was pending, LA Celino issued a Writ of Execution on August 20, 2018.
Petitioners tendered checks on September 11, 2018 to satisfy the judgment award and attendant fees, with a request for restitution in case of overpayment.
Cayabyab filed comments and subsequent pleadings, maintaining that the evidence presented by petitioners to negate the existence or applicability of the CBA was irrelevant and that the imposed legal interest was proper.

Whether the respondent, Cayabyab, is entitled to claim partial disability benefits under the purported Collective Bargaining Agreement (CBA) or whether the benefits should be determined solely under the provisions of the Amended POEA-SEC.

Did Cayabyab sufficiently prove the existence of the CBA through the documents tendered?
Was it established that his employment contract with VMC/SPMC was covered by the CBA at the time of his employment?
Did Cayabyab meet the conditions under the CBA—specifically, proving that his disability arose from an accident while performing his duties on board?

Whether the imposition of a six percent (6%) legal interest per annum on the monetary award is proper and in accordance with prevailing law and jurisprudence.

Does the absence of an express stipulation for the payment of interest in the pleadings preclude the award of such interest?
Is the application of the legal interest rate consistent with the principle that default interest is meant to compensate for the forbearance of money?