Case Summary (G.R. No. 204262)
Employment Background
Madridejos, a Filipino seafarer, signed an employment contract with NYK-Fil on March 25, 2010, for a position as a Demi Chef aboard the vessel "Crystal Symphony/Serenity." His contract was set for a duration of ten months, with provisions for salary and working conditions. He commenced his duties on April 10, 2010, but two weeks later, he suffered an accident resulting from slipping on a metal stairway, which led to the discovery of a sebaceous cyst.
Medical Treatment and Repayment
After his unfortunate fall on April 28, 2010, Madridejos was examined by onboard medical personnel and subsequently underwent a minor surgical procedure to excise the cyst at Spire Southampton Hospital on April 29, 2010. Following the procedure, Madridejos remained on the vessel until he was terminated on July 5, 2010, ostensibly due to the expiration of his contract as a probationary employee. He was repatriated to the Philippines on July 6, 2010.
Disability Claim Initiation
Upon returning to the Philippines, Madridejos sought recognition of his illness as work-related and demanded disability benefits from NYK-Fil. He claimed that his medical issues were aggravated by his work conditions and that he was advised to return home for further evaluation and treatment. Despite his assertions, NYK-Fil contested these claims, arguing that the cyst was not work-related and that Madridejos could resume his duties post-surgery.
Labor Arbiter's Decision
The Labor Arbiter, Gaudencio P. Demaisip, Jr., ruled in favor of Madridejos, concluding that his illness arose during his period of employment. The Labor Arbiter, however, awarded Madridejos a disability rating of Grade 7, rather than Grade 1, which he sought, based on the findings that while the illness was incurred during the employment term, there was insufficient evidence to indicate the severity warranted a higher classification.
National Labor Relations Commission (NLRC) Review
Both parties appealed the Labor Arbiter's ruling. The NLRC sided with NYK-Fil, highlighting significant doubts regarding the validity of Madridejos’s claims. They found that the cyst was not work-related and noted that there was no substantial proof supporting Madridejos's assertions of being medically unfit for work or the need for further treatment in the Philippines.
Court of Appeals Rulings
Madridejos subsequently filed for certiorari with the Court of Appeals, yet his petition was dismissed. The Court of Appeals upheld the NLRC's findings, stating that the evidence indicated Madridejos's termination resulted from the expiration of his contract rather than any medical issues. The court concluded that his medical condition did not arise through the course of his employment, thereby denying his claim for disability benefits.
Petition for Review on Certiorari
Madridejos proceeded to file a Petition for Review on Certiorari, asserting continued entitlement to disability benefits arguing the court decisions disregarded the substantial evidence he presented. He emphasized the need for recognition of his medical issues as arising from his occupational duties.
Court's Final Findings
The Supreme Court affirmed the lower courts' decisions, concluding that Madridejos's cyst was not work-relat
...continue readingCase Syllabus (G.R. No. 204262)
Case Overview
- Petitioner: Mario C. Madridejos
- Respondent: NYK-FIL Ship Management, Inc.
- Case Number: G.R. No. 204262
- Decision Date: June 07, 2017
- Division: Second Division
- Legal Issue: Entitlement to disability benefits due to an alleged work-related illness (sebaceous cyst).
Facts of the Case
- Madridejos was hired as a Demi Chef by NYK-FIL on March 25, 2010, for a 10-month contract.
- He began work on April 10, 2010, aboard the vessel "Crystal Symphony/Serenity."
- On April 28, 2010, he slipped on a metal stairway and fell, resulting in injuries.
- A sebaceous cyst was diagnosed and surgically removed on April 29, 2010, under local anesthesia.
- Madridejos was terminated on July 5, 2010, during the probationary period, due to the expiration of his contract.
- He claimed his medical condition led to the termination and sought disability benefits.
Legal Proceedings
- Madridejos filed a complaint for disability benefits before the Labor Arbiter.
- The Labor Arbiter found the illness incurred during employment but assigned a Disability Grade of 7, not the claimed Grade 1.
- Both parties appealed to the National Labor Relations Commission (NLRC).
- The NLRC ruled in favor of NYK-FIL, dismissing Madridejos' claims, stating that the cyst was not work-related.
- Madridejos filed a Petition for Certiorari with the Court of Appeals, which affirmed the NLRC decision.
Issues Raised
- Whether Madridejos was entitled to disability benefits for his s