Case Summary (G.R. No. 230919)
Factual Background
Antonio R. Jamias began his employment with the petitioners as a Cook AB under a six-month contract, which was governed by a Collective Bargaining Agreement (CBA). Jamias underwent a Pre-Employment Medical Examination (PEME) before boarding the vessel M/V Kwintebank. During his tenure, Jamias's duties involved heavy physical tasks, including lifting and carrying heavy provisions. In August 2011, while performing these duties, Jamias experienced abdominal pain and subsequently was diagnosed with constipation and an umbilical hernia, leading to his medical repatriation.
Medical Treatment and Findings
Upon his return to Manila, Jamias underwent further medical assessments. An MRI indicated significant spinal issues, specifically disc desiccation and a wide disc bulge at L5-S1, suggesting the presence of low back pain, which persisted post-surgery for umbilical hernia. Although he was declared fit to work in November 2011, Jamias sought further evaluation due to continued pain and eventually consulted an orthopedic specialist who attributed his back pain to a degenerative disc condition, classifying it as a Grade 8 disability under the POEA Contract.
Dispute over Claims
Upon submitting his disability claim to the Panel of Voluntary Arbitrators (PVA), the petitioners contested liability, asserting that Jamias's back issue was unrelated to his employment. They maintained that the focus was solely on the umbilical hernia—diagnosed and treated—arguing that back pain was not reported while he was employed. The PVA initially deemed it necessary for Jamias to undergo a third medical examination, which ultimately concluded that there was no connection between the back ailment and his earlier repatriation for the umbilical hernia.
PVA and Court of Appeals’ Rulings
The PVA awarded Jamias total and permanent disability benefits of $80,000. The petitioners appealed this decision to the Court of Appeals (CA), which held that despite the initial issues being the umbilical hernia, Jamias's back conditions should also be considered for compensation, as they manifested shortly after his repatriation and were documented during subsequent medical examinations.
The CA found that limiting the doctor's evaluation to solely the relationship between the umbilical hernia and the disc condition was inappropriate. It ordered that a proper determination of Jamias's entitlement to disability benefits must be made without restricting the medical inquiry.
Supreme Court’s Findings and Ruling
The Supreme Court examined the standard set forth in the POEA-SEC concerning compensation for injuries or illnesses manifested during or post-employment. It clarified that incapacity arising from any injury or illness, even if not directly causing repatriation, must be compensated as long as it was reported to the attending physician. The Court affirmed that the company-designated physician's failure to properly assess Jamias's
...continue readingCase Syllabus (G.R. No. 230919)
Background of the Case
- The case involves two petitions for review on certiorari, assailing the Court of Appeals' decision and resolution regarding seafarer Antonio R. Jamias and his claims for disability benefits against his employers, Blue Manila, Inc. and/or Oceanwide Crew Manila, Inc.
- The primary legal question is whether a seafarer's ailment must be a necessary consequence or directly connected to the cause of medical repatriation to be compensable.
Parties Involved
- Petitioners: Blue Manila, Inc. and/or Oceanwide Crew Manila, Inc., the manning agents of Wagenborg Crewmanagement BV, which owns the vessel M/V Kwintebank.
- Respondent: Antonio R. Jamias, a seafarer who worked for the petitioners since 1998.
Employment Details
- Jamias was rehired in February 2011 as Cook AB under a 6-month contract, covered by a collective bargaining agreement (CBA).
- His duties included preparing food, maintaining cleanliness, receiving provisions, and performing strenuous manual tasks like pushing and lifting heavy items.
Incident and Medical Condition
- In August 2011, while performing his duties, Jamias experienced abdominal pain and later diagnosed with an umbilical hernia after being repatriated to Manila on August 24, 2011.
- Post-repatriation, he underwent surgery for the hernia on September 24, 2011, which resolved his abdominal issues, but he continued to suffer from lower back pain.
Medical Evaluations and Findings
- The company-designated physician declared Jamias fit to