Case Summary (G.R. No. 124452)
Facts of the Case
Abella was deployed on March 20, 2016. On June 23, 2016, while handling a sack of rice, he experienced a sudden and sharp pain in his lower back, which he reported to his superiors. Initially treated with pain medication and a waist protector, his condition persisted, leading to a diagnosis of lumbar spondylosis and discopathy in Singapore. After further complications, he was repatriated to the Philippines on August 6, 2016, where he was diagnosed with a herniated disc at NGC Medical Specialist Clinic. Despite undergoing several treatments, Abella claimed that the respondents ceased treatment in February 2017 and received an assessment rating him with Grade 8 disability.
Initial Assessments and Claims
On February 20, 2017, during a conference, the respondents informed Abella of his Grade 8 disability status and offered corresponding benefits. When Abella sought further treatment or a better settlement, his requests were denied. A medical assessment by Dr. Cesar H. Garcia on April 25, 2017, indicated permanent unfitness for sea duty, prompting Abella to file a complaint for total and permanent disability benefits on May 24, 2017. He asserted that the failure of the company-designated physician to issue a timely final medical assessment justified his claim for total disability.
Labor Arbiter's (LA) Decision
The Labor Arbiter dismissed Abella’s complaint in a January 25, 2018 decision, concluding he was only entitled to Grade 8 disability benefits amounting to $16,795. The LA emphasized that the medical assessments from the company-designated physician held greater weight, given their comprehensive nature compared to Dr. Garcia's assessment based solely on a single examination. The LA acknowledged the timely issuance of the company-designated physician's assessment as sufficient to support the conclusion that Abella was not totally and permanently disabled.
NLRC Decision
The National Labor Relations Commission (NLRC) affirmed the LA's decision on May 24, 2018, denying Abella's appeal for total permanent disability benefits. The NLRC upheld the November 22, 2016 assessment over Dr. Garcia’s assessment, noting that the latter was made without the benefit of comprehensive medical tests. Furthermore, the NLRC stated that the results of tests ordered by a third doctor did not directly establish total disability without a proper third-party assessment being secured.
Court of Appeals (CA) Decision
Abella's petition for certiorari to the CA was denied, affirming the NLRC's findings. The CA noted that Abella failed to provide substantial evidence in his favor. It stated that the absence of a medical assessment from a third doctor further substantiated the validity of the company-designated physician’s assessment. The CA reiterated that a seafarer's inability to work after a certain number of days does not automatically entitle them to total and permanent disability benefits.
Petition for Review on Certiorari
In seeking a review, Abella argued he was entitled to total and permanent disability benefits, contending that the respondents failed to complete the conflict-resolution process, which undermined the validity of their claims. He maintained that medical tests supported his claim of enduring disability.
Court’s Ruling
The Supreme Court found merit in Abella's petitio
...continue readingCase Syllabus (G.R. No. 124452)
Case Overview
- The case involves a Petition for Review on Certiorari filed by Gregorio F. Abella against Abosta Shipmanagement Corporation, Panstar Shipping Co., Ltd., and Alex S. Estabilo.
- The petition challenges the Decision dated May 22, 2019, and the Resolution dated August 28, 2019, of the Court of Appeals, which upheld the Labor Arbiter's and NLRC's findings that Abella was only entitled to Grade 8 disability benefits.
Background Facts
- Abella was employed as an oiler by Abosta Shipmanagement Corporation, working under a 10-month contract on the vessel M/V Sino Trader, deployed on March 20, 2016.
- On June 23, 2016, while carrying supplies, Abella suffered a back injury, reporting immediate pain that radiated down his leg.
- He received initial treatment, including pain relievers and a waist protector, but his condition worsened, leading to medical consultations in Singapore and Brazil.
- Abella was repatriated to the Philippines on August 6, 2016, and received further medical evaluations, including a diagnosis of herniated discs and radiculopathy.
- Abella alleged that treatment was ceased by respondents on February 16, 2017, and was subsequently assessed with Grade 8 disability during a conference on February 20, 2017, with an offer for corresponding benefits.
Legal Proceedings
- Abella filed a complaint on May 24, 2017, claiming total and permanent disability benefits, medical expenses, and damages, against the denial from respondents for further treatment and benefits.
- The L