Case Summary (G.R. No. 255466)
Medical History and Initial Diagnosis
Esteva's condition escalated, leading to a diagnosis of lumbar disc prolapse by Dr. W. Watson on October 5, 2012, confirming temporary total disability. Upon his return to the Philippines on October 7, 2012, Esteva underwent further evaluations. The company-designated physician, Dr. Mylene Cruz-Balbon, later issued various medical certificates indicating he suffered from Pott's disease and a Grade 8 disability rating. Esteva also sought evaluations from other physicians who deemed his disability as total and permanent.
Procedural History and Labor Arbiter's Decision
Esteva filed a complaint for total disability benefits, including substantial claims under the CBA. The Labor Arbiter granted Esteva's claims, giving more credence to independent medical evaluations over the company-designated physician's assessments. The Arbiter's decision awarded Esteva US$90,000 for disability compensation, supported by findings of the independent physicians.
National Labor Relations Commission (NLRC) Ruling
The NLRC affirmed the Labor Arbiter's ruling, emphasizing that the company-designated physician’s assessment exceeded the acceptable period for temporary disability. This led to the conclusion that Esteva had been rendered permanently disabled—the decision indicated a clear threshold of incapacity beyond the stipulated maximum treatment duration of 240 days.
Court of Appeals Decision
The Court of Appeals deviated from the Labor Arbiter’s and NLRC’s conclusions, adopting the company-designated physician's assessment that rated Esteva as partially disabled. The Court ruled that Esteva failed to properly contest this assessment by not following the procedure to seek a third physician's opinion as prescribed in the POEA Standard Employment Contract, which led to an annulment of the previous awards.
Petitioner’s Arguments before the Supreme Court
Esteva petitioned the Supreme Court asserting that the referral to a third doctor, while a proper procedure, was not mandatory as he was not properly informed of the company-designated physician’s evaluation results timely. He claimed that respondents had not communicated their physician's assessments, depriving him of the right to contest them effectively. Furthermore, he contested the reliance the Court of Appeals placed on the company-designated physician’s assessment and argued that the lapse of time rendered his disability permanent.
Legal Framework and Evaluation
The legal framework for disability benefits under Philippine maritime law, particularly the POEA Standard Employment Contract, requires clear assessments of a seafarer's medical conditions. According to prevailing jurisprudence, the company-designated physician’s authority is foundational, but procedural rights, such as seeking a third physician, must be acknowledged to ensure fairness. The Court underscored that non-compliance with mandatory referral procedures can undermine a seafarer’s claims but that, in this case, the failure to disclose assessments was equally pivotal.
Supreme Court Findings and Conclusion
The Supreme Court evaluated the circumstances around the ti
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Case Background
- This case involves a Petition for Review on Certiorari filed by petitioner Jessie C. Esteva against respondents Wilhelmsen Smith Bell Manning, Inc. and Wilhelmsen Ship Management concerning the denial of his claim for total and permanent disability benefits.
- The case originated from the Court of Appeals' ruling, which annulled the previous decisions of the Labor Arbiter and the National Labor Relations Commission (NLRC) favoring Esteva.
- Esteva was employed as a seafarer and suffered from a back injury during his service aboard the vessel Ikan Bagang.
Employment and Medical History
- Esteva was hired on January 26, 2012, with a nine-month contract and a monthly salary of US$675.00, and was declared fit for work after a medical examination.
- He began experiencing severe back pain while onboard in June 2012 and was subsequently diagnosed with lumbar disc prolapse in October 2012 by Dr. W. Watson in South Africa.
- Esteva was repatriated to the Philippines on October 7, 2012, where he received further medical assessments from the company-designated physician, Dr. Mylene Cruz-Balbon, and other doctors, leading to conflicting diagnoses regarding his disability.
Claims and Initial Rulings
- Esteva filed a complaint for total permanent disability benefits, seeking US$90,000.00 under the Collective Bargaining Agreement (CBA), sickness allowance, medical reimbursements, moral and exemplary damages, and attorney's fees.
- The Labor Arbiter ruled in favor of Esteva, awarding him disability compensation based on findings from his doctors, which indicated a total and permanent disability.
- The NLRC affirmed this decision, reiterating that Esteva was permanently disabled due to the