Case Summary (G.R. No. 239390)
Applicable Law
The governing law applicable to the case is the 2010 Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC), which outlines the rights and obligations of seafarers and their employers concerning work-related injuries and illnesses.
Antecedents of the Case
Jerry J. Racela was hired on March 21, 2013, as a fitter on a vessel owned by Norbulk Shipping UK. His employment contract designated an eight-month duration and prescribed various salary and benefit terms. After undergoing a medical examination, Racela was cleared as "Fit for Sea Duty." In June 2013, he reported to work but began experiencing health problems in February 2014, leading to hospitalization and ultimately open-heart surgery for severe aortic regurgitation.
Upon his repatriation on April 19, 2014, Racela underwent further medical evaluations, which identified complications including aortic valve stenosis. Despite ongoing treatment, the company-designated physician concluded that his ailment was hereditary and not work-related, hence no disability rating was given.
Labor Arbiter's Ruling
In his April 19, 2016 decision, Labor Arbiter Thomas T. Que ruled in favor of Racela, granting him total and permanent disability benefits. The Arbiter argued that the ongoing medical treatment provided by the petitioners implied acknowledgment of an employer's liability, suggesting that Racela's condition was aggravated by work. The Arbiter concluded that Racela was entitled to benefits since his condition was unresolved and he was deemed totally disabled.
NLRC's Reversal
The National Labor Relations Commission (NLRC) later reversed the Arbiter's ruling on September 28, 2016. The NLRC contended that there was insufficient evidence to establish a causal connection between Racela's heart disease and his employment. It noted that various risk factors for aortic valve stenosis were not related to work conditions but stemmed from hereditary or lifestyle factors. The NLRC deemed Racela's heart condition non-compensable under the existing POEA standards.
Court of Appeals' Decision
On February 15, 2018, the Court of Appeals reinstated the Labor Arbiter's decision, asserting that Racela's condition was indeed work-related. The CA based its reasoning on the absence of working symptoms prior to employment and the stresses associated with maritime work. It also criticized the lack of definitive assessments and found that the company-designated physician's failure to issue a clear disability rating indicated that Racela was entitled to the benefits claimed.
Petitioners' Arguments
In their appeal, petitioners argued that the CA incorrectly attributed Racela's condition to work-related factors without substantial evidence. They maintained that Racela could not prove that his duties had aggravated his heart condition and emphasized that the medical assessments corroborated non-work-related factors as the primary cause of Racela's ailments. The petitioners further highlighted procedural deficiencies concerning Racela's non-referral to a third physician for additional evaluation.
Respondent's Counterarguments
Racela contended that the CA's ruling was consistent with POEA guidelines, emphasizing that his medical issues surfaced during his employment. He argued that his employer’s failure to respond to his request for a referral and other procedural claims reinforced his position of being considered totally and permanently disabled under the law.
Supreme Court's Ruling
The Supreme Court ultimately sided with the petitioners, finding that the NLRC's assessment was more al
...continue readingCase Syllabus (G.R. No. 239390)
Case Overview
- This case arises from an appeal by Bright Maritime Corporation and Norbulk Shipping UK Limited against the February 15, 2018 Decision and May 9, 2018 Resolution of the Court of Appeals (CA).
- The CA reversed the September 28, 2016 Decision and October 27, 2016 Resolution of the National Labor Relations Commission (NLRC) Fifth Division.
- The CA reinstated the Labor Arbiter's (LA) Decision dated April 19, 2016, which awarded total and permanent disability benefits and attorney’s fees to Jerry J. Racela (respondent).
Antecedents
- Jerry J. Racela was hired on March 21, 2013, by Bright Maritime Corporation to work as a fitter on a vessel owned by Norbulk Shipping UK Limited.
- The employment contract specified an 8-month duration with a basic monthly salary of US$600.00 and other terms, including overtime compensation and vacation leave pay.
- Respondent underwent a medical examination before employment and was declared "Fit for Sea Duty as Engine Rating."
- After reporting to the vessel in June 2013, he began to experience chest pains and difficulty breathing in February 2014.
- Respondent was diagnosed with severe aortic regurgitation and an aneurysm, underwent open-heart surgery on March 25, 2014, and was repatriated on April 19, 2014, for medical reasons.
Medical Evaluation and Treatment
- Upon repatriation, Jerry Racela was treated at Chinese General Hospital and continued to consult with the company-designated physician.
- The physician assessed his condition and noted no disability grading due to the aortic valve stenosis being pre-existing or hereditary.
- Respondent sought a second opinion from Dr. Efren R. Vicaldo, who declared him unfit for sea duty and rated his disability at Grad