Case Summary (G.R. No. 223246)
Overview of the Case
This case arises from Jan Frederick Pineda De Vera's petition for review, seeking to contest the rulings of the Court of Appeals that upheld the decision of the National Labor Relations Commission (NLRC), which denied him total and permanent disability benefits following a medical issue while employed as a bar attendant on a vessel.
Employment and Medical History
De Vera was employed by United Philippine Lines, Inc., under a contract verified by the Philippine Overseas Employment Administration. He reported back pain while on duty, underwent medical assessment, was referred to physicians, and was ultimately deemed fit to work after a series of treatments. Contrastingly, a physician he subsequently consulted declared him unfit for work.
Labor Arbiter's Initial Ruling
The Labor Arbiter initially ruled in favor of De Vera, awarding him total and permanent disability benefits after concluding that he was unable to resume work due to his medical condition, despite the assessments of the company-designated physicians stating he was fit for work.
NLRC's Reversal of the Labor Arbiter's Decision
The NLRC reversed the Labor Arbiter’s decision, citing concerns over the medical opinion rendered by De Vera’s physician, which was based on a single consultation compared to the multiple assessments by the company-designated physicians. The NLRC also emphasized that De Vera executed a Deed of Release and Quitclaim shortly after his fit-for-work declaration, essentially admitting to the correctness of the company’s physicians' assessments.
Court of Appeals Ruling
The Court of Appeals affirmed the NLRC’s findings, highlighting that De Vera's claim was premature as he had not challenged the company-designated physicians' assessment adequately by engaging an independent third doctor, as required under the POEA-SEC. The appellate court further ruled that De Vera failed to convey his disagreement with the medical assessment prior to filing his complaint.
Legal Issues Raised by De Vera
De Vera argued that he should be entitled to total and permanent disability compensation and contended that obtaining an independent medical opinion was not mandatory. Furthermore, he challenged the validity of the Deed of Release and Quitclaim, alleging that it was executed under duress.
Court's Ruling
The Court found De Vera’s assertions unmeritorious, establishing that his entitlement to disability benefits is governed by both the applicable Philippine laws and the contract provisions contained in the POEA-SEC. The court ruled that the appropriate procedures were not followed—especially the failure to seek a third-party medical evaluation—which precluded his claim for benefits. The assessment made by the company-designated physicians was upheld as valid and credible, especially given the supporti
...continue readingCase Syllabus (G.R. No. 223246)
Case Overview
- Court: Supreme Court of the Philippines
- Date of Decision: June 26, 2019
- G.R. No.: 223246
- Parties Involved:
- Petitioner: Jan Frederick Pineda De Vera
- Respondents: United Philippine Lines, Inc. and/or Holland America Line Westour, Inc., and Denny Ricardo C. Escobar
- Nature of Petition: Petition for Review on Certiorari
- Decisions Reviewed:
- August 20, 2015 Decision and February 5, 2016 Resolution of the Court of Appeals (CA)
- February 21, 2014 Decision and March 27, 2014 Resolution of the National Labor Relations Commission (NLRC)
- November 28, 2013 Decision of the Labor Arbiter
Facts of the Case
- Employment Details:
- De Vera was employed by UPLI on July 13, 2012, as a Bar Attendant on the vessel "M/S Statendam" for a duration of 10 months.
- His employment contract was verified and approved by the Philippine Overseas Employment Administration (POEA).
- Medical Condition:
- On December 15, 2012, De Vera reported lower back pain while on board.
- He was placed under medication for two weeks with temporary relief.
- An MRI performed on January 18, 2013, revealed moderate degenerative disc disease.
- De Vera underwent physical therapy as prescribed and returned to Manila on February 3, 2013, for further evaluation.
- Medical Assessments:
- Company-designated physicians initially evaluated De Vera and later cleared him as fit to work after extensive treatment and rehabilitation.
- De Vera filed a complaint for total and permanent disability benefits on April 18, 2013, but acknowledged receipt of final sick pay shortly after.
Labor Arbiter's Ruling
- Decision Date: November 28, 2013
- Ruling Summary:
- The Labor Arbiter found De Vera totally and permanently disab