Case Summary (G.R. No. 220657)
Petitioner's Employment and Incident
Celestino was employed by Pacific Ocean Manning, Inc. for 16 years, and he entered into a nine-month employment contract on January 24, 2011, to work as a Fitter on board the vessel MCT Monte Rosa. He was declared fit for work after a pre-medical examination before deployment. However, on June 15, 2011, he suffered an eye injury from a detached hose while performing maintenance work, and his requests for immediate medical attention were denied.
Medical Evaluation and Diagnosis
After further complications and a collapse on September 11, 2011, Celestino was referred to an offshore physician in the United States, where diagnostic imaging revealed a partial tear in the posterior retina, among other conditions. Following these findings, he was medically repatriated to the Philippines on September 21, 2011, but was not referred to a company-dispatched physician upon his return.
Claim for Benefits
On February 10, 2012, Celestino filed a complaint seeking payment for disability benefits, sickness allowance, and damages against his employers, claiming those injuries were work-related. The respondents contended that he finished his contract and denied that his medical conditions arose from work-related incidents, asserting that no proper medical examination was requested within the mandated timeframe after his repatriation.
Initial Rulings
The Labor Arbiter dismissed Celestino's complaint, citing non-compliance with the mandatory three-day post-employment medical examination requirement. The National Labor Relations Commission (NLRC), however, later reversed this decision, recognizing that Celestino had sustained work-related injuries that warranted disability benefits.
Court of Appeals Decision
The respondents subsequently sought a petition for certiorari at the Court of Appeals (CA), which ruled against the NLRC's decision, reinstating the Labor Arbiter's dismissal based on the purported failure to adhere to reporting and examination protocols.
Supreme Court Review
The Supreme Court found merit in Celestino's petition, stating that the issues regarding his medical repatriation and compliance with mandatory reporting requirements were questions of fact deserving review. The Court noted that Celestino was still within the duration of his employment contract when he was repatriated and emphasized that the absence of pertinent medical assessments from the company-designated physician—despite clear indicators of incapacity—was an infringement of Celestino's rights under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC).
Findings on Medical Condition and Reporting
The Court substantiated that Celestino was indeed medically repatriated and complied with the reporting requirement under Section 20 of the POEA-SEC by seeking medical attention within two days of his return. The employer’s failure to refer him to a medical examination post-repatriatio
...continue readingCase Syllabus (G.R. No. 220657)
Background of the Case
- The case revolves around a petition for review on certiorari by Celestino M. Junio (petitioner) against Pacific Ocean Manning, Inc., Mega Chemical Tanker, and Erlinda S. Azucena (respondents).
- The primary issue is whether Celestino is entitled to disability benefits due to an incident that occurred while he was employed as a Fitter on board the MCT Monte Rosa.
Antecedents
- Celestino worked with Pacific Ocean Manning, Inc. for sixteen years and signed a nine-month contract on January 24, 2011, to serve aboard the MCT Monte Rosa starting January 30, 2011.
- Prior to deployment, he underwent a pre-medical examination and was declared fit to work.
- On June 15, 2011, an accident occurred where a hose struck his left eye, but his request for medical examination was denied due to the vessel's impending departure.
- On September 11, 2011, Celestino collapsed while performing his duties and was subsequently referred to Dr. Daniel Jenkins III for medical attention.
- Following an MRI, he was diagnosed with a partial tear of the posterior retina and other health issues. Notably, Dr. Jenkins indicated that Celestino's illnesses were not work-related.
- Celestino was repatriated on September 21, 2011, but upon his return, he was not referred to a company-designated physician despite multiple requests for medical treatment.