Case Summary (G.R. No. 131803)
Factual Background
On May 10, 2016, Ramon S. Langam was employed as the chief cook by Pacific Ocean Manning, Inc. for the vessel "Cochrane." After undergoing a pre-employment medical examination, he was declared fit for sea duty. On January 2, 2017, while cooking, hot oil splashed into his right eye, causing immediate pain. Despite trying to wash it out and continuing with his activities, he later experienced persistent pain and blurred vision. He sought medical aid first from the ship's doctor and then in Korea, where an attending physician deemed him unfit for duty.
Following his medical repatriation on January 5, 2017, Langam pursued a post-medical evaluation, which indicated a grave prognosis from the company-designated physician, who noted that he was unlikely to regain normal vision. His requests for further evaluations and disability benefits were met with refusals from the petitioners, citing confidentiality of medical records.
Medical Consultation and Findings
Langam then sought a second opinion from independent medical experts, including Dr. Eileen Faye Enrique-Olanan and Dr. Michael Bravo, both confirming his condition of optic atrophy and his unfitness for sea service due to impaired vision. Respondents requested a third medical opinion and sought payment of disability benefits, to which petitioners objected, insisting that disability benefits were only for accidental disabilities and that his medical condition did not warrant such compensation.
Panel of Voluntary Arbitrators (PVA) Ruling
The PVA ruled in favor of Langam, indicating that the petitioners had failed to respond adequately to his requests and that their previous medical assessments were biased. The PVA awarded Langam permanent total disability benefits and attorney's fees, stating that petitioners were not forthcoming in their evaluations.
Court of Appeals (CA) Ruling
The CA upheld the PVA's decision, emphasizing the credibility of Langam's chosen medical experts. The CA reiterated that he was entitled to full disability benefits based on the inability to return to work due to the medical findings.
Supreme Court's Ruling
The petitioners contested the CA's ruling, arguing that their assessment was valid and should prevail. The Supreme Court pointed out that the key issue was whether Langam was entitled to total permanent disability benefits. It reiterated the conditions laid out in the POEA Standard Employment Contract, emphasizing workers' rights and the process for seeking disability benefits.
The Supreme Court concluded that Langam's medical issues developed during his employment and qualified for coverage under the POEA guidelines. However, it also noted that the initial assessment of Grade 7
...continue readingCase Syllabus (G.R. No. 131803)
Overview of the Case
- The case is a petition for review on certiorari filed by Pacific Ocean Manning, Inc. and its principal companies against Ramon S. Langam concerning the latter's entitlement to disability benefits following an injury sustained while on duty.
- The petition aims to reverse the Decision dated December 12, 2018, and the Resolution dated March 21, 2019, issued by the Court of Appeals in CA-G.R. SP No. 157086.
Employment Background
- Ramon S. Langam was employed as a chief cook by Pacific Ocean Manning, Inc. for its principal, V Ships UK Ltd./Southern Shipmanagement Co. S.A., on the vessel "Cochrane."
- Prior to his assignment, Langam underwent a pre-employment medical exam, which deemed him fit for sea duty.
Incident and Medical Condition
- On January 2, 2017, while working, hot cooking oil splashed into Langam's right eye, leading to immediate pain.
- After washing his eye, he continued working but experienced persistent pain, swelling, and blurred vision.
- Initially treated by the ship's doctor, he was later referred to a hospital in Korea due to inadequate medical facilities on board.
Medical Assessments and Treatments
- In Korea, a physician declared Langam unfit for duty to rule out serious conditions affecting his eyesight.
- Upon repatriation on January 5, 2017, he sought a post-medical evaluation from the company-designated physician, Dr. Carter S. Rabo, at Chinese Medical Hospital.
- Dr. Rabo's prognosis indicated that Langam was unlikely to recover normal vision, and treatment continued with minimal improvement.
Dispute Over Medical Assessments
- Langam's family sought an independent eval