Case Summary (G.R. No. 139436)
Antecedent Facts
Julius Rey Quinal Doble, the respondent, was employed as an Ordinary Seaman under a Contract of Employment established with DOHLE (IOM) Ltd. The contract lasted nine months, offering a basic monthly salary of US$350 and stating the terms of work hours and benefits. Following his departure from the Philippines on August 22, 2012, Doble experienced various injuries while working aboard the vessel MVTS Jakarta. Subsequent to these injuries, he reported to the ship's doctor but was initially cleared to work. Upon his repatriation on April 11, 2013, he was found to suffer from a series of ailments and underwent surgery, leading to his claim for disability benefits.
Labor Arbiter's Decision
On November 27, 2014, the Labor Arbiter (LA) ruled in favor of Doble, declaring him permanently disabled and entitled to a compensation of US$90,882, along with attorney's fees. The LA concluded this based on Doble's condition and the medical reports presented, including assessments from both the petitioners’ and his own medical practitioners.
NLRC's Affirmation
The petitioners challenged the LA's decision, but the National Labor Relations Commission (NLRC) affirmed the ruling, noting that Doble was indeed entitled to the benefits claimed due to his state of disability. The NLRC's decision further affirmed Doble's claims without modification.
Court of Appeals' Ruling
Upon appeal, the Court of Appeals (CA) upheld the NLRC decision but revised the legal basis for the award from the Collective Bargaining Agreement (CBA) to the provisions of the POEA-SEC, ultimately granting Doble a permanent total disability benefit of US$60,000.
Issues Presented
The issues for consideration included whether Doble was fit to work and entitled to the claimed disability benefits, the appropriateness of using the CBA versus the POEA-SEC as the legal basis for the award, and whether Doble should receive attorney's fees.
Supreme Court's Ruling
The Supreme Court found merit in the petitioners' claims, noting that only questions of law are generally reviewable in a petition for review on certiorari. The Court emphasized the need to adhere to the POEA-SEC provisions governing the assessment of disability. The Court specifically cited the absence of a third-party physician assessment, a prerequisite when conflicting medical opinions arise.
Analysis of Medical Assessments
The Court reviewed the divergent conclusions from the company-designated physician, who deemed Doble fit to work, and Doble’s personal physician, who argued he was permanently disabled. It underscored the procedural mandate requiring referral to a third doctor in case of disagreements regarding medical assessments; the fai
...continue readingCase Syllabus (G.R. No. 139436)
Case Background
- The case involves two consolidated petitions for review on certiorari filed by DOHLE Philman Manning Agency, Inc., DOHLE (IOM) Ltd., and Capt. Manolo T. Gacutan against Julius Rey Quinal Doble.
- The petitions challenge the Decision of the Court of Appeals (CA) in CA G.R. SP No. 141199, which modified the National Labor Relations Commission (NLRC) Resolution dated March 18, 2015.
- The respondent, Julius Rey Quinal Doble, is a Filipino seafarer who signed a Contract of Employment for nine months with a basic monthly salary of US$350.00, detailing a 44-hour work week and benefits.
Antecedent Facts
- Respondent departed for the MVTS JAKARTA on August 22, 2012.
- He sustained injuries on two separate occasions while working aboard the vessel: once in December 2012 (right foot injury) and again in March 2013 (carpal tunnel syndrome).
- After repatriation, he was diagnosed with multiple conditions, including a right ankle sprain and bilateral carpal tunnel syndrome.
- The company-designated physician issued an interim disability grade, declaring him fit to work by November 8, 2013, contrary