Case Summary (G.R. No. 252199)
Contractual Employment Details
Caraan’s employment contract began on August 29, 2013, for a duration of nine months, entailing a basic monthly wage of US$689.00. He was to work 44 hours per week with provisions for overtime, vacation, and other benefits. He underwent a pre-employment medical examination (PEME) and was certified fit for work before embarking on his assignment.
Medical Condition and Repatriation
While performing his duties, Caraan faced challenging working conditions resulting in health issues, including pain while urinating and the discharge of blood, ultimately leading to a diagnosis of urinary tract infection (UTI) and chronic prostatitis. Despite receiving initial treatment in Japan, he was medically repatriated to the Philippines on June 1, 2014, where he immediately sought medical care due to his deteriorating condition.
Claims for Disability Benefits
Upon his return, Caraan claimed total disability benefits and damages, citing his unfitness to work due to severe health issues diagnosed as renal cell carcinoma after further examinations. He argued that the filing of his claims was justified despite not reporting to the designated company physician within three days of his repatriation due to his incapacitating illness.
Initial Ruling by the Voluntary Arbitrators (PVA)
The PVA sided with Caraan, stating he had demonstrated substantial compliance with the reporting requirement. The panel determined that the circumstances surrounding his incapacity justified his failure to report to the designated physician. They ruled in favor of granting his disability benefits amounting to US$90,000.00, alongside attorney’s fees.
Court of Appeals' Reversal
The Court of Appeals reversed the PVA's decision, citing Caraan's failure to comply with post-employment medical examination protocols as dictated by the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC). The appellate court did not accept that his notification through his spouse constituted sufficient communication regarding his medical condition.
Supreme Court's Review and Ruling
In reviewing the case, the Supreme Court acknowledged the discrepancy in factual findings between the PVA and the Court of Appeals, thus necessitating a reevaluation of the evidence. The Court reaffirmed that the requirement to report within three days is not an absolute condition for disability claims and should be assessed in light of the circumstances surrounding an applicant's health status and ability to comply.
The Supreme Court drew parallels to prior cases where the failure to report was excused under similar circumstances, emphasizing the broader intent of labor laws to provide protection to workers. The Court ruled that Caraan was indeed entitled to the benefits he claimed, recognizing that his
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Antecedents
- Celso B. Caraan (petitioner) filed a complaint for total disability benefits, damages, and attorney's fees with notice to arbitrate before the National Conciliation and Mediation Board (NCMB).
- Petitioner was employed by Grieg Philippines, Inc. (Grieg PH) since 2006, signing a contract on August 29, 2013, for a nine-month term as a Motorman with a monthly wage of US$689.00.
- Job responsibilities included strenuous physical activities and exposure to harmful conditions, leading to health issues.
- After medical attention in Japan for urinary problems, he was repatriated on June 1, 2014, due to being declared unfit to work.
- Upon return to Manila, Grieg PH did not assist him, and he sought medical attention using a company-issued health card.
- Subsequent medical examinations revealed serious health issues, including a mass in his left kidney, leading to a diagnosis of renal cell carcinoma.
Ruling of the Panel of Voluntary Arbitrators (PVA)
- On March 5, 2016, the PVA ruled in favor of petitioner, awarding him US$90,000.00 for permanent and total disability benefits.
- Key findings included:
- Petitioner complied with the 3-day reporting requirement by having his wife inform Grieg PH about his medical condition.
- Although there was no post-employment examination by the company-designated physician, the examination by his chosen doctors was sufficient.
- Illness was compensable under Section 32(a) of the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC).
- Petitioner was not gainfully employed for over 240 days due to his med