Case Summary (G.R. No. 247338)
Factual Background
On April 13, 2016, the Petitioner was hired and subsequently declared fit for duty after a Pre-Employment Medical Examination. He reported for work on May 1, 2016. The issue arose in October 2016 when the Petitioner experienced severe back pain while performing his duties. He requested medical help but was denied and was eventually repatriated on October 17, 2016. Upon returning to Manila, a company-designated physician diagnosed him with Degenerative Disc Disease, for which he received treatment and later was declared fit to work again on December 5, 2016. However, on January 25, 2018, a different physician assessed him as unfit for sea duty.
Arbitration Outcome
The Petitioner sought disability compensation from the Respondents, which was denied. He then filed a notice to arbitrate for permanent and total disability benefits, damages, and attorney’s fees. The Voluntary Arbitrator (VA) dismissed the complaint for lack of merit, emphasizing the findings of the company's designated physician, the Petitioner's signed Certificate of Fitness to Work, and the absence of substantial evidence linking his condition to his work.
Court of Appeals Ruling
The Court of Appeals (CA) dismissed the petition for review filed by the Petitioner as being one day late. The CA concluded that since the Petitioner did not adhere to the stipulated timelines provided for appeals under Rule 43 of the Revised Rules of Civil Procedure, his petition was deemed invalid and untimely.
Legal Issue
The primary legal issue presented before the Supreme Court revolves around the timeliness of the Petitioner's appeal and whether the Court of Appeals was correct in dismissing it for being one day late.
Supreme Court's Ruling
The Supreme Court found merit in the Petitioner's circumstances, referencing the 2018 case of Guagua National Colleges v. CA. It clarified that the correct period to file an appeal after receiving an adverse decision from a VA is fifteen days from receipt of the resolution denying a motion for reconsideration. In this instance, the Petitioner received the Resolution of the VA's decision on November 22, 2018, thereby granting him until December 7, 2018, to file his appeal. Since he filed on
...continue readingCase Syllabus (G.R. No. 247338)
Case Background
- The case involves a petition for review on certiorari filed by Roger V. Chin against Maersk-Filipinas Crewing, Inc., Maersk Line A/S, and Renel C. Ramos.
- The petition assails the Resolutions dated December 19, 2018, and May 9, 2019, issued by the Court of Appeals (CA) which dismissed Chin's appeal for being filed late.
- The underlying dispute arose from Chin’s employment as an Able Seaman and subsequent claims for disability benefits after an injury sustained on the job.
Facts of the Case
- Roger V. Chin was hired on April 13, 2016, on a six-month contract aboard the vessel MV Maersk Danube under a Collective Bargaining Agreement.
- After passing a Pre-Employment Medical Examination, he began working on May 1, 2016.
- In October 2016, while performing his duties, he experienced severe back pain and symptoms resembling a heart attack, leading to his medical repatriation on October 17, 2016.
- Upon returning to Manila, he was treated by Dr. Ferdinand Bernal and was diagnosed with Degenerative Disc Disease but was declared fit to work on December 5, 2016.
- Chin subsequently sought a second opinion from Dr. Cesar H. Garcia on January 25, 2018, who deemed him unfit for duty.
- After his request for disability compensation was den