Case Summary (G.R. No. 238261)
Facts
On January 27, 2012, Manolo signed a nine-month employment contract with Singa Ship Management, Inc. to work as a chef de partie on board the vessel "Queen Mary 2." After experiencing health issues characterized by difficulty swallowing solid food and persistent cough, he was evaluated in Hamburg, where he was diagnosed with a large ulcerted mass in his nasopharynx. Following medical repatriation to the Philippines on July 27, 2012, he received a definitive diagnosis of nasopharyngeal carcinoma and underwent treatment from a company-designated physician, who later assigned him a disability rating of Grade 7 post-treatment. Tragically, Manolo died on February 15, 2014, prompting his heirs to file a complaint against his employer for the recovery of death benefits, claiming that his illness was work-related.
Labor Arbiter's Ruling
The Labor Arbiter ruled in February 2015 that SSMI and affiliated companies were jointly and severally liable for disability benefits totaling $50,000 for permanent total disability, plus $14,000 for his two children. The Arbiter determined that Manolo's condition was work-related due to his poor dietary conditions aboard the vessel, and the disability rating contradicted statements of non-work-related illness.
NLRC Ruling
The National Labor Relations Commission issued a decision on January 29, 2016, reversing the Labor Arbiter's ruling. It concluded that the Heirs of Manolo were not entitled to death benefits, as his death occurred more than a year after termination of employment due to medical repatriation. However, it permitted the possibility of filing a separate action for disability benefits.
CA Ruling
The Court of Appeals, in October 2017, reversed the NLRC ruling concerning disability benefits, ordering SSMI to provide a benefit total of $20,900, while upholding the lack of entitlement to death benefits. The CA affirmed that the company-designated physician had sufficiently established a work-related connection to Manolo's illness.
Issues Before the Court
The primary issue examined was the CA's award of disability benefits to the Heirs of Manolo. SSMI contended that the CA erred in awarding these benefits, asserting the illness was not work-related. Conversely, the Heirs claimed that the CA should have awarded death compensation benefits, given that Manolo's death resulted from a work-related injury.
Court's Ruling
The Court denied SSMI's petition while granting the Heirs' petition. It emphasized that despite Manolo's death occurring post-repatriation, his death resulted from a work-related illness, thus satisfying the criteria for compensation under the 2010 POEA Standard Employment Contract. The Court noted that the presumption of work-relatedness was not effectively rebutted by SSMI, and reiterated that a disability rating typically signifies a work-related injury, which, in this case, was established by the designated physician's consistent assessments.
Work-Rela
...continue readingCase Syllabus (G.R. No. 238261)
Case Background
- This case involves two consolidated petitions for review on certiorari stemming from a dispute regarding the entitlement of the heirs of Manolo N. Licuanan to benefits following his death.
- The petitions challenge the Decision dated October 12, 2017, and the Resolution dated March 22, 2018, of the Court of Appeals (CA), which reversed prior rulings by the National Labor Relations Commission (NLRC).
- The NLRC had previously granted disability benefits and attorney's fees to the heirs of Manolo, who died on February 15, 2014, after being diagnosed with nasopharyngeal carcinoma.
Facts of the Case
- Manolo signed a nine-month contract on January 27, 2012, to work as a chef de partie on board the vessel "Queen Mary 2."
- He began his duties on March 7, 2012, but developed serious health issues by July 2012, including difficulty swallowing and persistent cough.
- An ENT specialist diagnosed him with a large ulcerated mass in the nasopharynx in Hamburg, Germany, recommending a biopsy.
- Manolo was medically repatriated to the Philippines for further evaluation on July 27, 2012, where he was diagnosed with nasopharyngeal carcinoma on August 17, 2012.
- His condition was initially deemed not work-related, but a subsequent assessment on November 23, 2012, attributed a Grade 7 disability rating to his illness, which became final on December 14, 2012.
- After his death, the heirs filed a complaint for recovery of death benefits and damages against the employers, asserting that his illness was work-related.