Case Summary (G.R. No. 164301)
Facts of the Case
Cutanda was hired by Marlow Navigation Phils. for a ten-month contract with a monthly salary of US$680. Before joining the vessel MV "Malte Rambow," he was declared fit to work by company-designated physicians. On October 8, 2012, he suffered severe injuries to his left hand while executing his duties aboard the vessel in Malaysia. After immediate medical care in Malaysia, he was repatriated to the Philippines for further treatment, where he underwent therapy for approximately six months but remained unfit for work.
Legal Actions Taken
Following the inadequate response from his employers regarding his medical condition and their refusal to pay disability benefits, Cutanda filed a complaint against the respondents pursuing total disability benefits, medical reimbursements, moral damages, and attorney’s fees. He asserted that his injuries had rendered him permanently and totally disabled, warranting compensation as per the regulations under the Philippine Overseas Employment Administration (POEA) Standard Employment Contract (SEC).
Findings in Lower Courts
The Labor Arbiter initially ruled in favor of Cutanda, granting him the full amount of US$60,000 in disability benefits, US$6,000 in attorney’s fees, and P50,000 for moral damages. The ruling underscored the notion that disability assessments are determined not solely by the company physician but also by the medical findings demonstrating the extent of the injuries.
The National Labor Relations Commission (NLRC) affirmed this ruling, pointing out the conflicting medical assessments which delegitimized the determination made by the company-designated physician regarding the petitioner's disability grading.
Court of Appeals Decision
The respondents appealed to the Court of Appeals (CA), which reversed the NLRC's decision, claiming Cutanda's disability was graded at "Grade 10" and thus did not meet the criteria for total and permanent disability established under the POEA-SEC. The CA further deleted the awards for moral damages and attorney's fees, arguing insufficient grounds for these claims.
Supreme Court Determination
Upon review, the Supreme Court reconciled the conflicting findings between the CA and the NLRC, ultimately siding with Cutanda. The ruling stated that the findings by the company physicians did not conclusively prove that Cutanda was fit to work or had regained the full use of his hand, thereby qualifying him for permanent total disability benefits given the duration he had been unable to work, exceeding the legal limits.
The Court
...continue readingCase Syllabus (G.R. No. 164301)
Overview of the Case
- The case involves a Petition for Review on Certiorari filed by Desiderio C. Cutanda against Marlow Navigation Phils., Inc., and others.
- The petition seeks to reverse and set aside the Decision and Resolution of the Court of Appeals, which overturned the earlier decision of the National Labor Relations Commission (NLRC) that granted Cutanda total and permanent disability benefits amounting to US$60,000.00, attorney's fees of US$6,000.00, and moral damages of P50,000.00.
Background Facts
- Desiderio C. Cutanda was employed as a Key Able Seaman aboard the MV "Malte Rambow" by Marlow Navigation Phils., Inc. for a ten-month contract, with a monthly salary of US$680.00.
- Prior to employment, he was declared "fit to work" by the company-designated physicians.
- Cutanda had prior employment with the respondents for fifteen years before this contract.
- On October 8, 2012, while performing his duties, Cutanda suffered severe injuries to his left index and middle fingers due to an accident involving a tug's line while docked at the Port of Tanjung, Pelepas, Malaysia.
- Following the accident, he received emergency medical treatment and was repatriated to the Philippines on October 9, 2012, where he was diagnosed with lacerated wounds and underwent rehabilitation.
Legal Proceedings
- After months of physical therapy, Cutanda remained unfit to work and demanded his disability benefits, which the respondents failed to provide.
- Cutanda filed a complaint for total disability benefits, medical expenses