Title
Westminster Seafarer Management Philippines, Inc. vs. Raz
Case
G.R. No. 249344
Decision Date
Apr 5, 2022
The Supreme Court upholds Arnulfo C. Raz's entitlement to disability benefits with legal interest and attorney's fees due to a shoulder injury sustained while employed as a seafarer.
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Case Digest (G.R. No. 249344)

Facts:

  • The case involves Westminster Seafarer Management Philippines, Inc. (petitioner) and Arnulfo C. Raz (respondent).
  • Raz entered into a Contract of Employment on November 10, 2014, to work as a Fitter on the vessel NOCC Kattegat for nine months.
  • The petitioner acted as the agent of Wallem Shipmanagement Limited.
  • Raz's duties included repairing and maintaining the vessel's engine, which involved lifting heavy equipment.
  • On May 15, 2015, Raz suffered severe pain in his right shoulder while lifting a heavy cylinder head.
  • After reporting the injury, he was referred to a physician in Southampton, London, and was repatriated on May 31, 2015, after being declared unfit for work.
  • Upon returning to the Philippines, further medical examinations revealed multiple shoulder injuries, leading to surgery on July 8, 2015.
  • Raz was assessed with a Grade 9a disability by the company-designated physician but was not deemed permanently unfit for work.
  • A second opinion from another physician declared him permanently unfit for any sea duties.
  • Raz filed a complaint with the National Conciliation and Mediation Board (NCMB) for total permanent disability benefits, medical reimbursement, damages, and attorney's fees.
  • The NCMB ruled in favor of Raz on June 20, 2017, awarding him a total of US$129,212.00 in benefits, US$10,000.00 in moral damages, and 10% of the total award as attorney's fees.
  • The petitioner sought reconsideration, which was denied, and the Court of Appeals (CA) later reduced the disability benefit to US$25,313.00 while affirming the attorney's fees and legal interest.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, affirming the Court of Appeals' decision dated May 6, 2019, and the resolution dated September 12, 2019.
  • The Court upheld the imposition of 6% legal inter...(Unlock)

Ratio:

  • The Court noted that the awarded amount of US$25,313.00 was binding, as neither party contested it further.
  • The petitioner's claim of having satisfied the judgment award lacked supporting evidence, as no documentation of payment was provided.
  • Legal interest at 6% per annum applies from the finality of the judgment...continue reading

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