Case Summary (G.R. No. 233071)
Facts
Jose Elizalde B. Zanoria was employed as a Chief Mate aboard the vessel Brilliant Sky with a monthly salary of $1,427. On March 27, 2014, while in Atlanta, USA, he was diagnosed with various eye conditions resulting in blurred vision, which led to his medical repatriation to the Philippines. He was examined by the company-designated physician, Dr. George C. Pile, who assessed him as unfit for work due to a work-oriented medical condition. Despite undergoing surgery for a cataract, Zanoria was later declared unfit to work as a seafarer, leading to the initiation of grievance proceedings.
Proceedings and Initial Decision
Following a series of failed negotiations and the declaration of a deadlock, Zanoria filed a Notice to Arbitrate with the NCMB. The Panel of Voluntary Arbitrators ruled on February 19, 2016, declaring him permanently disabled and ordering the petitioners to pay disability benefits totaling $159,914 and sickness allowances.
Appeal to the Court of Appeals
Petitioners filed for a petition for review under Rule 43 of the Revised Rules of Court, contesting the award of disability benefits and sickness allowances. The CA affirmed the ruling of the Panel of Voluntary Arbitrators on March 7, 2017, but modified the permanent disability benefit to $60,000 while sustaining the rest of the original decision.
Supreme Court Issue
The central issues presented to the Supreme Court were whether the CA committed serious errors in awarding total and permanent disability benefits, sickness allowances, and attorney's fees to the respondent. Additionally, the petitioners argued that the respondent had taken subsequent employment while his claim was pending, which should negate his disability claim.
Findings of the Court
The Supreme Court upheld the decisions of the CA and the Panel of Voluntary Arbitrators, stating that the question of whether the CA erred was largely factual and not within the purview of the Supreme Court's review under Rule 45. It emphasized that the partial disability assessment presented by the company-designated physician contradicted the declaration of unfitness for work, effectively reclassifying the condition to a permanent disability.
Medical Certification and Permanent Disability
The Court noted the inconsistency in Dr. Pile's medical certification, where a partial disability grading conflicted with the overall declaration of being unfit for work. It clarified that such inconsistencies lead to the conclusion of permanent total disability under prevailing law an
...continue readingCase Syllabus (G.R. No. 233071)
Case Overview
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioners Magsaysay Maritime Corp. and Keymax Maritime Co., Ltd. seek to reverse and set aside the Decision dated March 7, 2017, and the Resolution dated July 25, 2017 of the Court of Appeals.
- The Court of Appeals affirmed with modification the Decision dated February 19, 2016, of the National Conciliation and Mediation Board (NCMB) Panel of Voluntary Arbitrators.
Antecedents
- Jose Elizalde B. Zanoria was hired as Chief Mate on board the vessel Brilliant Sky on March 21, 2013, with a monthly salary of US$1,427.00.
- His duties included ensuring the safety of the ship, crew, passengers, and cargo, and overseeing loading and unloading operations.
- On March 27, 2014, while in Atlanta, USA, he was diagnosed with several eye conditions, including a macular hole and traumatic cataract.
- Respondent was medically repatriated to the Philippines on April 2, 2014, where he underwent further examinations and treatments.
- Dr. George C. Pile, the company-designated physician, diagnosed him as unfit to work and recommended further medical procedures.
Medical Developments
- Respondent underwent phacoemulsification surgery on May 23, 2014, after which he had follow-up consultations.
- On August 13, 2014, Dr. Pile informed respondent that he was unfit to work as a seafarer and would receive a disability grading.
- Despite requests, respond