Case Summary (G.R. No. 193468)
Background of Employment and Injury
Eyana was employed by PTCI for a contract period of eight months with specific duties involving manual labor. His injury occurred on August 2, 2006, when lifting a heavy block of cheese resulted in severe back pain. Following hospitalization in Oslo and repatriation to the Philippines, he received treatment, including consultations with Dr. Natalio G. Alegre II, the company-designated physician, and Dr. Venancio P. Garduce, Jr., a private orthopedic specialist.
Medical Findings and Treatment History
Dr. Alegre's initial assessment indicated severe low back pain, and subsequent examinations revealed disc-related issues with nerve compression. Throughout his treatment, Eyana continued physical therapy but was hesitant to undergo surgery. Eventually, Dr. Alegre assigned Eyana a Disability Grade of Eight, while Dr. Garduce later assessed his condition as Grade One, declaring him unfit for sea duty.
Proceedings Before the Labor Arbiter and NLRC
Eyana filed a complaint for disability benefits before the NLRC after the LA awarded him US$80,000 as total and permanent disability benefits in light of the CBA provisions. The NLRC, however, reversed this decision, stating that Eyana's medical condition did not meet the threshold for total and permanent disability under the provisions of the POEA-SEC.
Court of Appeals Ruling
The CA upheld the NLRC decision, underscoring that a claimant must provide contrary medical evidence to contest a company-designated physician’s findings. It noted Eyana's delay in seeking a second opinion from Dr. Garduce and classified Dr. Alegre’s evaluations as having more probative weight due to his extensive examinations of Eyana.
Legal Issues Presented
The Supreme Court's review focused on two main issues: the applicability of the CBA provisions regarding compensation for loss of profession and the jurisprudential standard regarding total and permanent disability. Eyana contended that the provisions of the CBA entitled him to full compensation irrespective of the specific disability grade assigned.
Supreme Court Ruling
The Supreme Court partially granted the petition. It emphasized the need for substantial evidence to support claims related to disability benefits. Due to Eyana's inability to provide authenticated evidence supporting the CBA’s claims, the Court found that the relevant provisions
...continue readingCase Syllabus (G.R. No. 193468)
Case Background
- The case involves a petition for review on certiorari concerning the decisions made by the Court of Appeals (CA) and the National Labor Relations Commission (NLRC) regarding the disability compensation of Al O. Eyana (the petitioner).
- The CA affirmed the NLRC's decision, which awarded the petitioner disability compensation equivalent to Grade Eight under the Philippine Overseas Employment Agency (POEA) Standard Employment Contract (SEC).
- The NLRC had reversed an earlier decision by the labor arbiter that awarded the petitioner a total of US$80,000.00 in permanent disability benefits and US$8,000.00 in attorney's fees.
Parties Involved
- Petitioner: Al O. Eyana
- Respondents: Philippine Transmarine Carriers, Inc. (PTCI), Alain A. Garillos (crewing manager of PTCI), and Celebrity Cruises, Inc. (CCI).
Employment Details
- The petitioner was hired by PTCI, on behalf of CCI, for the position of utility cleaner on board the M/V Century, effective April 15, 2006, under an eight-month contract with a monthly salary of US$267.00.
- His responsibilities primarily involved manual tasks, including lifting and transporting food supplies.
Incident and Medical Treatment
- On August 2, 2006, the petitioner experienced severe back pain after lifting a 30-kilo block of cheese, subsequently reporting the incident to his superior.
- He was hospitalized in Oslo, Norway from August 4 to 16, 2006, and repatriated to the Philippines on August 17, 2006.
- Upon returning, he was referred to Dr. Natalio G. Alegre II for treatment, who noted severe low back pain and recommended physical therapy.
- The petitioner underwent several consultations and treatments, including physical therapy and medication, but exhibited persistent pain and mobility issues.