Case Summary (G.R. No. 222523)
Background and Initial Claims
Guerrero was employed by PTCI and represented by Salinas on behalf of CC for a contract period of six months, beginning on October 12, 2011, with a salary of USD 255.00 per month. He underwent a pre-employment medical examination and was deemed fit for work. On January 15, 2012, he was involved in an incident while assisting elderly guests during a shipboard gastro-intestinal outbreak, which led to back pain. Guerrero claimed that this pain developed into a serious spinal condition requiring extensive medical treatment, including surgery.
Respondents' Defense
In response to Guerrero's claims, the respondents contended that the injury did not occur during a work-related activity but rather during a gym incident on January 22, 2012. They presented documents, including the Crew Injury Statement, supporting their assertion that Guerrero's injury arose from his personal gym activities rather than his duties as a Casino Dealer.
Labor Arbiter Ruling
The Labor Arbiter ruled in favor of Guerrero on February 28, 2013. They affirmed that PTCI and CC were solidarily liable for Guerrero's permanent disability benefits, attributing the injury to Guerrero’s work despite respondent claims of a gym-related origin. The ruling noted Guerrero’s incapacity for more than 120 days post-repatriation, ordering the respondents to pay him USD 60,000, excluding Salinas as a party to the case.
NLRC Appeal and Ruling
Respondents appealed to the National Labor Relations Commission (NLRC), which reversed the Labor Arbiter's decision on July 31, 2013. The NLRC concluded Guerrero did not provide sufficient evidence to prove that his injury was work-related, dismissing his claims for lack of merit. Guerrero's motion for reconsideration was subsequently denied.
Court of Appeals Decision
Guerrero then filed a petition for certiorari before the Court of Appeals (CA), which upheld the NLRC's decision on September 10, 2015. The CA found no grave abuse of discretion on the part of the NLRC and reaffirmed that Guerrero’s injury did not stem from a work-related activity, denying his claims for disability benefits and damages.
Supreme Court Ruling
The Supreme Court found Guerrero's petition without merit. It emphasized that the case primarily involved a factual inquiry regarding the nature of Guerrero’s injury, which had been consistently determined by the lower courts to be non-work-related. The Court reiterated that the burden of proof lay with Guerrero to establish a causal connection between his employment and his injury. It ruled that Guerrero had failed to demonstrate this link with substantial evidence, restating that findings of fact by the NLRC, upheld by the CA, are generally conclusive.
Legal Principles Applied
The Supreme Court underscored the significance of two essential criteria for comp
...continue readingCase Syllabus (G.R. No. 222523)
Case Overview
- This case involves a petition for review on certiorari filed by Jose John C. Guerrero against Philippine Transmarine Carriers, Inc. (PTCI), Celebrity Cruises (CC), and Carlos C. Salinas.
- The petition seeks to reverse the September 10, 2015 Decision and January 14, 2016 Resolution of the Court of Appeals in CA-G.R. SP No. 132711.
- The main issue revolves around Guerrero's claim for permanent and total disability benefits, compensatory damages, exemplary damages, moral damages, and attorney's fees.
Background of the Case
- Guerrero was employed as a Casino Dealer on board the vessel GTS Constellation starting October 12, 2011.
- He was declared "fit to work" after a pre-employment medical examination.
- In January 2012, during a gastrointestinal outbreak, Guerrero assisted elderly passengers using wheelchairs, which he claims led to a back injury.
- Post-incident, Guerrero experienced severe back pain and sought medical attention, resulting in a diagnosis of Lumbar Spondylosis and subsequent surgery.
Medical Evidence and Diagnosis
- Guerrero underwent several medical evaluations, including an MRI which indicated significant spinal changes.
- He later received a medical certificate from Dr. Cesar H. Garcia stating he was "UNFIT for further sea service."
- The injury was initially reported as resulting from a gym incident, contradicting Guerrero's claims of a work-related injury.
Respondents' Position
- The respondents contended that Guerrero's injury was not work-related but rather occurred during a gym work