Case Summary (G.R. No. 211972)
Background and Employment Contract
On September 6, 2002, Illescas signed a Contract of Employment to serve as Third Officer for a period of nine months, with a monthly salary of US$854.00, complying with the Philippine Overseas Employment Administration (POEA) Standard Contract for Seafarers. After a pre-employment medical exam, he began working on October 6, 2002. Despite a relatively good start, an incident on May 16, 2003, involving the lifting of fire hydrant caps, led to severe back pain for Illescas.
Injury and Medical Treatment
Illescas suffered an injury on May 17, 2003, when he felt a snap in his back while handling heavy equipment. Initially managed with pain relievers, his condition worsened to the point where he was treated at a clinic in Japan, diagnosed with lumbago and advised to limit heavy lifting. Subsequently, Illescas was repatriated on June 14, 2003, and diagnosed with serious spinal issues following tests in the Philippines. Despite undergoing surgery on August 27, 2003, his condition remained such that he could not perform his previous duties.
Claim for Disability Benefits
On December 16, 2003, Illescas, through counsel, demanded payment for disability benefits. The claim was assessed by a local correspondent of the P&I Club connected to Barber Ship Management. An initial offer of US$16,795.00 was rejected by Illescas, who asserted his accident and subsequent disability fell under his Collective Bargaining Agreement (CBA) entitling him to US$90,000.00.
Legal Proceedings and Initial Rulings
The issue escalated through the NLRC after Illescas filed a complaint. The Labor Arbiter ruled in favor of Illescas, granting him the full amount of US$90,000.00 as per the CBA, citing his injury as an unforeseen accident. Petitioners appealed this decision, leading to the NLRC upholding a modification that awarded only US$16,795.00, arguing that the injury was not an accident as defined by the CBA.
Court of Appeals Decision
Dissatisfied with the NLRC's ruling, Illescas sought recourse from the Court of Appeals, which overturned the NLRC's decision on October 23, 2007. The appellate court concluded that Illescas's injury was indeed the result of an accident while performing his duties, and the CBA provisions were applicable. The Court of Appeals reinstated the award of US$90,000.00 in benefits.
Award of Attorney’s Fees
The Court of Appeals also granted Illescas attorney's fees, asserting that he incurred costs in protecting his rights due to the actions of the petitioners. The appellate court justified this award under relevant provisions of the Labor Code and Civil Code.
Supreme Court Evaluation
The principles at stake were examined by the Supreme Court, emphasizing the definitions and interpretations of an "acci
...continue readingCase Syllabus (G.R. No. 211972)
Case Background
- This case arises from a petition for review on certiorari filed by petitioners NFD International Manning Agents, Inc. and Barber Ship Management Ltd., challenging the Decision of the Court of Appeals dated October 23, 2007, and its subsequent Resolution dated May 9, 2008.
- The Court of Appeals annulled the decision of the National Labor Relations Commission (NLRC), mandating the petitioners to pay respondent Esmeraldo C. Illescas the sum of US$90,000.00 as disability benefits, along with attorney's fees.
Employment Contract and Incident
- Respondent entered into a Contract of Employment on September 6, 2002, as Third Officer aboard M/V Shinrei for nine months, with a monthly salary of US$854.00.
- The employment contract adhered to the Philippine Overseas Employment Administration (POEA) Standard Contract for Seafarers.
- Respondent began his duties on October 6, 2002, but on May 17, 2003, while carrying heavy fire hydrant caps, he experienced a back injury leading to severe pain, which he communicated to the ship's captain.
Medical Treatment and Diagnosis
- Respondent was diagnosed with lumbago and sprain at a clinic in Japan and was later deemed unfit for work by a doctor in Australia.
- Upon returning to the Philippines, further examinations revealed serious spinal issues, including multi-level disc desiccation and severe canal stenosis.
- He underwent laminectomy and discectomy on August 27, 2003, but continued to experience significant mobility restrictions.
Disability Assessment
- Dr. Marciano F. Almeda J