Case Summary (G.R. No. 250584)
Applicable Law
The provisions of the 1987 Philippine Constitution apply as the decision date falls in 2021. Relevant statutes include the Philippine Overseas Employment Administration (POEA) Standard Employment Contract (SEC) and applicable labor laws regarding disability.
Case Background
Petitioner Christopher C. Calera initiated a claim for total and permanent disability benefits due to a lower back injury allegedly sustained on December 7, 2016, while preparing to embark on a vessel in Cartagena, Colombia. Calera claimed that the injury was work-related and sought remedies under his employment contract and the POEA SEC. His employment history includes a medical certification declaring him fit for sea service before deployment, following which he reported his injury and continued to suffer from severe pain which ultimately led to his medical repatriation.
Events Following Injury
After his medical repatriation, Calera underwent various evaluations and treatments in the Philippines, including physical therapy for persistent low back pain diagnosed initially as mechanical lumbago and perianal abscess. Despite undergoing multiple sessions of physical therapy, the respondent allegedly terminated his treatment prematurely. Disagreements arose regarding the determination of his fitness for work, leading Calera to seek disability compensation.
Panel of Arbitrators' Ruling
Initially, the Panel of Arbitrators ruled in favor of Calera, granting him total and permanent disability benefits, asserting the respondent's conclusions regarding the nature of his injuries were erroneous given Calera's consistent complaints of back pain. However, the Arbitrators denied claims for sickness allowance and other damages, concluding there was no misconduct on the part of the respondent in handling Calera’s claims.
Proceedings in the Court of Appeals
The respondent appealed the decision to the Court of Appeals, which reversed the Arbitrators’ ruling, finding that the injury was neither accidental nor work-related because it occurred in a hotel bathroom, outside the confines of claimed employment hazards. The Court concluded that Calera’s injury was a consequence of routine wear and tear associated with prolonged strenuous work, rather than an accident linked to shipboard activities.
Supreme Court's Ruling
Upon further appeal, the Supreme Court found merit in Calera’s petition, emphasizing the need to recognize the compensability of work-aggravated conditions resulting from employment-related activities, even when the initial injury occurs outside direct work circumstances. The Court noted that although the incident in the hotel bathroom did not constitute a compensable accident, the subsequent exacerbation of Calera’s injury due to the demanding nature of his seafarer duties qualified him for disability benefits under Section 20(A) of the POEA SEC.
Criteria for Disability Benefits
The Supreme Court established that to qualify for total and permanent disability be
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Case Overview
- Petitioner: Christopher C. Calera
- Respondent: Hoegh Fleet Services Philippines, Incorporated
- Case Number: G.R. No. 250584
- Date of Decision: June 14, 2021
- Division: Second Division
- Legal Issue: Petitioner contests the Court of Appeals' decision which held that his illness was neither accident-related nor work-related, and the subsequent denial of motion for reconsideration.
Antecedents
- Petitioner filed a Notice to Arbitrate on July 24, 2017, seeking total and permanent disability benefits for a lower back injury sustained while preparing to board a vessel in Cartagena, Colombia.
- Employed as an ordinary seaman since 2014, he was declared fit for sea duties before his deployment in December 2016.
- On December 7, 2016, he slipped in the bathroom of the Holiday Inn Hotel, leading to severe back pain that worsened due to strenuous work aboard Hoegh Grace.
- Multiple medical assessments documented his condition, revealing mechanical lumbago and a perianal abscess, ultimately leading to his repatriation on January 4, 2017.
Medical Evaluations and Treatment
- Initial medical assessments in Cartagena diagnosed him with mechanical lumbago; subsequent checks revealed worsening conditions including a perianal abscess.
- Upon repatriation, he was referred to Shiphealth, Inc. for further evaluation and underwent multiple physical therapy sessions.
- Despite treatment, an orthopedic specialist later assessed him as suffering from total and permanent disability, declaring him unfit for sea duty.
Grievance Proceedings and Arbitration
- Petitioner request