Case Summary (G.R. No. 140500)
Antecedents
Acabado's employment commenced on March 16, 2015, and he reported various injuries stemming from his work activities shortly thereafter. Following an incident on August 23, 2015, where he injured his knees, and an accident falling from stairs the next day, he was examined by physicians who diagnosed him with a "meniscus tear." Despite subsequent diagnoses indicating issues with both knees, Acabado faced challenges in obtaining comprehensive medical benefits from the petitioners.
Rulings of the Labor Arbiter (LA) and NLRC
On March 2, 2017, the LA found that the petitioners failed to issue an appropriate assessment of Acabado's disability within the required timelines, entitling him to full benefits of 60,000 USD. The NLRC later modified this ruling, upholding a Grade 10 disability rating based on the company-designated physician's evaluations, awarding 10,075 USD instead.
Ruling of the Court of Appeals (CA)
The CA subsequently overturned the NLRC's decision on June 21, 2019. It reinstated the LA’s ruling with modifications, ruling that Acabado was entitled to the full 60,000 USD in permanent total disability benefits on the grounds that the company-designated physician failed to provide a conclusive disability rating within the allowed periods, therefore establishing a presumption of permanent and total disability.
Arguments of the Petitioners
The petitioners contended that the CA erred in its conclusions. They asserted that Acabado was not entitled to total and permanent disability benefits as the company-designated physician had declared him as Grade 10 disabled. They also alleged procedural errors on Acabado's part for not obtaining a third doctor's opinion prior to pursuing his claims, along with a contested assertion regarding the entitlement to attorney’s fees.
The Court's Ruling
The Supreme Court denied the petition, affirming the CA's judgment. It reiterated the ruling that the duty of the company-designated physician to provide a final disability assessment is critical. Failure to do so renders any prior findings ineffective and leads to the automatic classification of the seafarer's
...continue readingCase Syllabus (G.R. No. 140500)
Background of the Case
- The case involves a Petition for Review on Certiorari filed by Hartman Crew Philippines and Sea Giant Shipmanagement, Ltd., seeking to overturn the Court of Appeals' Decision dated June 21, 2019, and Resolution dated September 18, 2019.
- The petitioners aim to reinstate the ruling of the National Labor Relations Commission (NLRC) which ordered them to pay Randy V. Acabado a lower amount for disability benefits.
Antecedents
- Randy V. Acabado, employed as a Wiper by Hartman, sustained injuries while working on M/T Gaschem Rhone.
- His employment commenced on March 16, 2015, and the injuries occurred on August 23 and 24, 2015, leading to a diagnosis of a "meniscus tear" on his right knee.
- Acabado underwent surgery on September 16, 2015, followed by physical therapy until April 4, 2016.
- He reported his condition after returning to the Philippines and underwent assessments from various doctors, including Dr. Natalio Alegre II, who provided disability assessments that were contested by Acabado.
Ruling of the Labor Arbiter (LA)
- The LA found that the respondents failed to issue a proper disability grading within the required 240-day period following Acabado's repatriation.
- The LA awarded Acabado US$60,000.00 for total and permanent disability benefits and 10% attorney's fees.
Ruling of the NLRC
- The NLRC modified the LA's decision, awarding Acabado US$10,075.00 pl