Case Summary (G.R. No. 168716)
Petition Overview
- The petition seeks to reverse the decisions of the Court of Appeals regarding the entitlement of respondent Ronaldo R. Pilar to disability compensation.
- The case involves the employment of Pilar as a crew member on the M/V Hual Triumph, where he experienced health issues leading to his repatriation.
Employment Terms and Health Issues
- Pilar was employed under a contract specifying a duration of nine months, a monthly salary of $981, and other benefits.
- He reported health issues, including loss of appetite and severe nervousness, shortly after boarding the vessel.
- Diagnosed with depression and gastric ulcer in Japan, he was declared unfit for work and repatriated to Manila.
Medical Treatment and Evaluation
- Upon return, Pilar received treatment from HFS-designated physician Dr. Nicomedes G. Cruz, who confirmed his major depression.
- Other physicians also evaluated Pilar, with varying opinions on his fitness for work and additional health issues, including chronic gastritis.
Legal Proceedings Initiated by Pilar
- Pilar filed a complaint for underpayment of disability and medical benefits, claiming entitlement under the Collective Bargaining Agreement (CBA) due to an incident on board.
- The complaint was referred to the National Conciliation and Mediation Board (NCMB) due to Pilar's membership in the Associated Marine Officers and Seaman's Union of the Philippines (AMOSUP).
Petitioners' Defense
- Petitioners contended that Pilar's depression was not caused by an accident, thus he was not entitled to disability benefits under Article 12 of the CBA.
- They argued that he was only entitled to the 120-day sick pay under Article 10 of the CBA, which provides for medical examination and sick pay conditions.
NCMB Decision
- The NCMB ruled in favor of Pilar, stating that his psychological condition was compensable due to the nature of his work.
- They awarded him disability compensation of $90,000 and attorney's fees, citing the principle of social justice.
Court of Appeals Ruling
- The Court of Appeals upheld the NCMB's decision but clarified that Article 12 of the CBA did not apply since Pilar's illnesses were not the result of an accident.
- The CA affirmed Pilar's entitlement to benefits under Section 32 of the employment contract.
Key Legal Issues
- The primary issue was whether Pilar was entitled to disability pay, with petitioners arguing against the CA's ruling.
- The CA's decision emphasized the importance of the CBA and the circumstances under which Pilar fell ill.