Case Summary (G.R. No. 219495)
Facts of the Case
Cabatan reported feeling severe pain in the scrotal and inguinal areas after carrying heavy machinery aboard the M/V BP Pioneer due to waves causing the vessel to sway. Initially treated by the ship’s doctor, Cabatan was put on pain relievers and advised to rest, although no immediate serious conditions were diagnosed. After repatriation on May 25, 2010, he underwent a pre-employment medical examination (PEME) at a company-accredited clinic, which revealed multiple spinal issues, leading to consultations with various specialists and recommendations for surgery.
Procedural History
On March 1, 2011, Cabatan filed a complaint against SEASCORP and Maritime Management for total permanent disability benefits based on injury claims. The respondents contended that Cabatan failed to report to the manning agency for post-employment medical examination after contract termination and thus claimed he forfeited his right to benefits. The Labor Arbiter ruled in favor of Cabatan; however, the National Labor Relations Commission (NLRC) reversed this decision, primarily based on the contention that he did not substantiate that his condition was work-related or that he complied with post-employment reporting requirements.
NLRC Decision
The NLRC's April 26, 2012 decision emphasized the need for a seafarer to undergo a post-employment medical examination within three days upon repatriation, which Cabatan did not do. The Commission found the absence of evidence linking Cabatan’s alleged permanent disability directly to his employment and maintained that his claims were unsupported due to failure to comply with reporting protocols.
Court of Appeals Decision
Cabatan’s subsequent petition for certiorari before the Court of Appeals was denied, affirming the NLRC's findings that non-compliance with mandatory reporting requirements led to the forfeiture of his claims for disability benefits. The Court held that the controlling factor for entitlement to benefits was whether an examination could establish a link between the claimed disability and the employment.
Issues on Appeal
In the present petition for review on certiorari, Cabatan raised two main issues, arguing that the Court of Appeals erred in dismissing the “Report of Illness” from the ship’s doctor and that the mandatory reporting requirement should not be absolute as he did not believe his condition warranted medical attention based on initial medical advice.
Supreme Court Ruling
The Supreme Court ruled against Cabatan, holding that the petition lacked merit. Reaffirming the NLRC
...continue readingCase Syllabus (G.R. No. 219495)
Background of the Case
- The case involves a petition for review on certiorari filed by Reynaldo P. Cabatan against Southeast Asia Shipping Corp. and its principal, Maritime Management Services.
- The petition seeks to annul the January 23, 2015 Decision and July 20, 2015 Resolution of the Court of Appeals, which affirmed earlier rulings made by the National Labor Relations Commission (NLRC).
- Cabatan was employed as an oiler from 2006 to 2010 and alleges he sustained a work-related injury during his service on the vessel M/V BP Pioneer.
Employment and Incident Details
- Cabatan was certified fit for sea duty prior to his deployment, which began on January 30, 2010.
- On March 29, 2010, while performing his duties, Cabatan felt severe pain in his scrotal/inguinal area after carrying heavy spare parts during a 12-hour shift.
- After the incident, despite continuing to work, he reported pain and numbness in his left leg but was advised by the ship's doctor to rest and take pain relievers.
Medical Evaluations and Findings
- Following his repatriation on May 25, 2010, Cabatan underwent a series of medical examinations which revealed various spinal conditions, including spondylolisthesis and spinal stenosis.
- He sought surgery but was unable to afford the costs and requested financial assistance from SEASCORP, which went unaddressed.
- A complaint was filed on March 1, 2011, against the respondents for per