Case Summary (G.R. No. 207828)
Applicable Law
This case is governed by the provisions of the 2000 Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC) and relevant provisions of the Labor Code, specifically Articles 197 to 199 concerning disability benefits.
Employment Background and Medical Conditions
On August 7, 2008, Bautista entered into a nine-month employment contract with Elburg Shipmanagement Philippines, Inc. He was declared fit for sea duty after undergoing a Pre-Employment Medical Examination (PEME). During his employment, he experienced various health issues, including breathing difficulties and severe fatigue, which led to a suspicion of thoracic aneurysm and ultimately his medical repatriation on May 8, 2009. Upon returning, he was diagnosed with Hypertensive Cardiovascular Disease and Diabetes Mellitus II.
Claims for Disability Benefits
On September 16, 2009, Bautista filed a complaint seeking disabilities benefits under the collective bargaining agreement (CBA) that amounted to US$118,800. He argued that his illnesses were work-related due to the nature of his job, which rendered him unable to work within 120 days, thus qualifying his condition as permanent and total disability.
Respondent's Position
The respondents contended that Bautista’s Diabetes Mellitus II was familial and not work-related. They asserted that his hypertension was a complication arising from his diabetes, making it also not compensable. The respondents relied on the argument that because Diabetes Mellitus II is not considered an occupational disease, neither was the hypertension that followed.
Labor Arbiter's Ruling
In an initial ruling on February 19, 2010, the Labor Arbiter ordered the respondents to pay Bautista US$89,100 as total and permanent disability benefits. The Labor Arbiter acknowledged that Bautista's condition developed while employed and recognized the findings of his medical condition as reflective of work-related ailments.
NLRC Ruling
The National Labor Relations Commission (NLRC) upheld the Labor Arbiter's findings on September 20, 2010. It emphasized that, while Diabetes Mellitus II is not an occupational disease, the diagnosis of Hypertensive Cardiovascular Disease made it compensable. The NLRC found no evidence of pre-existing conditions that would disqualify Bautista's claim.
Court of Appeals Ruling
The Court of Appeals reversed the NLRC’s decision on September 6, 2012, asserting that Bautista failed to provide substantial evidence linking his conditions to his employment. It questioned the credibility of the medical evaluation from Bautista's presenting physician, Dr. Vicaldo, due to the lack of comprehensive medical testing.
Issue Before the Supreme Court
The central issue for resolution was whether the Court of Appeals erred in concluding that the NLRC had gravely abused its discretion by awarding Bautista disability benefits.
Court's Ruling
The Supreme Court f
...continue readingCase Syllabus (G.R. No. 207828)
Background of the Case
- The case involves a petition for review on certiorari filed by Jose Rudy L. Bautista against Elburg Shipmanagement Philippines, Inc., Augustea Shipmanagement Italy, and Captain Antonio S. Nombrado.
- This petition seeks to challenge the Decision dated September 6, 2012, and the Resolution dated February 19, 2013, of the Court of Appeals (CA), which reversed the rulings of the National Labor Relations Commission (NLRC) that had previously favored Bautista.
- The core issue revolves around Bautista's claim for total and permanent disability benefits, which was dismissed by the CA.
Facts of the Case
- Bautista entered a nine-month Contract of Employment with Elburg as Chief Cook on the vessel "MV Lemno" on August 7, 2008, and was declared fit for sea duty after a Pre-Employment Medical Examination (PEME).
- He commenced work on August 14, 2008, but soon experienced multiple health issues including breathing difficulty, severe fatigue, and dizziness while on duty.
- Upon medical referral, he was suspected of having a thoracic aneurysm, leading to his repatriation on May 8, 2009.
- After repatriation, he was diagnosed with "Hypertensive Cardiovascular Disease" and "Diabetes Mellitus II" at Metropolitan Medical Center (MMC).
- Bautista filed a complaint on September 16, 2009, seeking USD 118,800.00 in disability benefits, claiming his illnesses were exacerbated by his work environment.
Petitioner’s Claims
- Bautista argued that his medical conditions were occupational diseases related to the nature of his work and thus should be compensable under the Collective Bargaining Agreement (CBA).
- He contended that he was unable to re