Case Summary (G.R. No. 229179)
Background Facts
Riego was employed as a Chief Cook aboard the MV Hikari I, under a contract providing for a one-year term. After experiencing abdominal and lower back pain while onboard, he was repatriated for further medical attention and treated by several physicians. His medical assessments indicated various diagnoses, culminating in a report asserting he had a Grade 11 disability due to a one-third loss of lifting power, as determined by a company-designated physician.
Initial Rulings
The Labor Arbiter (LA) ruled in favor of Riego, awarding disability benefits based on the assessment by the company-designated physician. The National Labor Relations Commission (NLRC) affirmed this decision, noting no evidence of total disability as defined under the POEA-SEC.
Court of Appeals Ruling
The Court of Appeals reversed the NLRC's decision, declaring Riego permanently disabled and entitled to total disability benefits. The appellate court emphasized the lack of a final assessment within 120 days, which warranted a classification of his condition as permanent and total disability.
Supreme Court's Review
When the petition was brought before the Supreme Court, the central issue pertained to whether Riego suffered a total and permanent disability. Despite the company's arguments asserting the validity of the physician's assessments, the Court recognized the procedural implications of delayed medical assessments.
Evaluation of Medical Assessments
The Supreme Court referenced previous rulings, particularly in Elburg Shipmanagement Phils., Inc. v. Quiogue, outlining the burdens placed on the company-designated physician to issue conclusive assessments within specified timelines. It was found that the company-designated physician failed to provide a valid assessment within the required 240-day period, conclusively indicating Riego’s disability as permanent and total.
Conflict Resolution Mechanism
The Court highlighted the importance of the conflict resolution provisions within the POEA-SEC, detailing the responsibilities of both the employee and employer when faced with conflicting medical opinions. It held that due process requires both parties to engage in good-faith discussions to resolve conflicts over med
...continue readingCase Syllabus (G.R. No. 229179)
Case Background
- This case involves an appeal by certiorari filed by Benhur Shipping Corporation, Sun Marine Shipping S.A., and Edgar B. Bruselas against a decision by the Court of Appeals (CA) that awarded total and permanent disability benefits to the respondent, Alex PeAaredonda Riego.
- The appeal seeks to overturn the CA's September 30, 2016 decision and January 6, 2017 resolution, which annulled and set aside the ruling of the National Labor Relations Commission (NLRC).
Employment Details
- Riego was employed as a Chief Cook on the vessel "MV Hikari I" under a 12-month contract with a monthly salary of US$535.00.
- He was found fit to work during his pre-employment medical examination and subsequently boarded the vessel on October 8, 2013.
Incident and Medical Treatment
- In December 2013, Riego experienced abdominal and lower back pain while on board; he was treated in Thailand and later repatriated for further medical evaluation.
- Upon returning to the Philippines on December 15, 2013, he was referred to Dr. Robert D. Lim, the company-designated physician.
- Riego underwent multiple medical evaluations and treatments from December 16, 2013, to May 26, 2014, with various reports documenting his condition.
Medical Findings and Reports
- Initial assessments indicated normal results for many tests, but Riego was diagnosed with Hiatal Hernia and L4-L5, L5-S1 Disc Bulge.
- On May 26, 2014, the company-designated physician issued a final report stating Riego had a Grade 11 disability assessment, indicating a 1/3 loss of lifting power.
- Conversely, a second medical opinion from Dr. Fidel M. Magtira declared Riego permanently unfit to work in any capacity.
Legal Proceedings
- Riego filed a compla