Case Summary (G.R. No. 244437)
Applicable Law
The relevant legal framework governing this case is dictated by the 1987 Philippine Constitution, as the case decision date falls in 2020. Additionally, the Labor Code and the contractual obligations arising from seafarers' employment agreements are crucial in determining the rights of the parties involved.
Employment and Medical Background
Amadeo Pajares was employed as a Suite Attendant on board the cruise ship Silver Whisper, earning a basic monthly salary of USD 477.00. During his employment, he was exposed to potentially harmful cleaning chemicals, which he and his heirs believe contributed to his health deterioration. Following a severe nosebleed, Amadeo was diagnosed with Multiple Myeloma, a type of blood cancer, by a company-designated physician. Despite seeking further medical clarification and a second opinion, he faced challenges in obtaining medical documentation from his employer, which ultimately led to complications regarding his claims for benefits.
Findings of the Panel of Voluntary Arbitrators
The Panel of VAs initially dismissed the complaint from Amadeo concerning his disability benefits, stating that he had not provided sufficient evidence linking his illness to his work. They upheld the findings of the company-designated physician which concluded that Amadeo's condition was not work-related. Furthermore, significant weight was given to the medical report from the employer’s physician, whereas evidence from an independent physician was discounted due to the lateness of its submission. Despite the dismissal of claims for permanent disability benefits, the Panel awarded a financial assistance of USD 20,000.00 on humanitarian grounds.
Court of Appeals' Ruling
Upon appeal by North Sea regarding the financial assistance awarded, the Court of Appeals (CA) upheld the Panel of VAs' findings while modifying the financial assistance award to USD 8,500.00. The CA found that the heirs of Amadeo did not properly appeal for a reversal of the decision concerning disability benefits, as such claims were not included in the initial appeal made by North Sea. The petitioners' subsequent claims—including the legitimacy of their request for total disability benefits and other grievances related to due process—were not regarded favorably as they were not litigated in the prior proceedings.
Supreme Court's Decision
The Supreme Court affirmed the decision of the CA, reiterating that non-appellants are not entitled to affirmative relief after failing to appeal. The distinctions made by the Panel of VAs were upheld concerning the lack of evidence offered by petitioners against the employer’s medical findings, which sufficiently showed that Amadeo’s illness was not aggravated by his employment as a Suite Attendant. The refusal
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Background of the Case
- This case revolves around a Petition for Review on Certiorari filed under Rule 45 of the Rules of Court.
- The petitioners are the heirs of Amadeo Alex G. Pajares, who sought to challenge the Decision dated November 16, 2018, and the Resolution dated January 23, 2019, of the Court of Appeals (CA).
- The CA affirmed with modifications the October 30, 2017, Decision of the Office of the Panel of Voluntary Arbitrators (Panel of VAs), relating to a complaint for total and permanent disability benefits filed by Amadeo against North Sea Marine Services Corporation and its foreign principal V. Ships Leisure S.A.M. 'Les Industries,' along with Edwin T. Francisco.
Facts of the Case
- Amadeo entered into a shipboard employment contract with North Sea as a Suite Attendant on the vessel Silver Whisper, earning a monthly salary of US$477.00 for six months.
- The duties of a Suite Attendant included housekeeping tasks similar to those in five-star hotels, exposing Amadeo to strong and potentially harmful cleaning chemicals.
- Amadeo experienced severe nosebleeding and sought medical assistance on the ship before being diagnosed with Multiple Myeloma at Aleris Hamlet Private Hospital.
- Upon returning to the Philippines, he reported to North Sea and underwent further medical assessments that confirmed his illness.
- Amadeo faced challenges in obtaining his medical records from North Sea and sought a third medical opinion, which also confirmed his unfitness for sea service due