Case Summary (G.R. No. 109248)
Background of the Case
The petitioner companies, POMI and V. Ships UK Ltd., were involved in a dispute with respondent Nicolas F. Bobiles regarding his claim for total permanent disability compensation. Bobiles worked as a pumpman on the vessel Nordic Vega, and his employment contract, which had a basic salary of USD 764.00, was approved by the Philippine Overseas Employment Administration (POEA). After sustaining a back injury on January 27, 2017, Bobiles was diagnosed with severe lumbar spine injuries, and his capacity to work as a seaman was significantly impacted.
Injury and Medical Treatment
Upon inspection of the vessel’s equipment, Bobiles experienced a back injury that led to debilitating pain. Despite undergoing medical treatment and therapies both abroad and in the Philippines, he continued to suffer from severe stiffness and pain that rendered him unable to fulfill his duties as a seaman. A series of medical evaluations confirmed deteriorating conditions, ultimately leading to a second opinion that deemed Bobiles permanently disabled and unfit for seafarer duties.
NCMB Decision and Appeals
The National Conciliation and Mediation Board (NCMB) ruled in favor of Bobiles, determining his disability was total and permanent, and awarded him USD 102,308 for disability compensation along with attorney's fees. Subsequently, the Court of Appeals modified the NCMB’s award, reducing the compensation to USD 60,000, emphasizing that the company's physician delayed issuing a final assessment, thus prompting legal recognition of Bobiles' permanent disability.
Petitioners' Arguments
In their petition to the Supreme Court, POMI and V. Ships UK Ltd. contended that Bobiles failed to pursue the resolution process involving a third doctor and that the delay in the medical assessment was justified. They further argued against Bobiles’ claim for attorney’s fees, stating that the absence of bad faith from their part should preclude such an award.
Judicial Interpretation of Attorney's Fees
The Supreme Court clarified that under Article 111 of the Labor Code, attorney’s fees are only recoverable in cases involving unlawful withholding of wages, which was not applicable here as the case pertained to disability compensation. Additionally, Article 2208 of the Civil Code was examined, specifically regarding recovery of attorney’s fees. The court noted that the provisions cited by the lower courts for awarding attorney’s fees—spe
...continue readingCase Syllabus (G.R. No. 109248)
Case Background and Parties
- Petitioners Pacific Ocean Manning, Inc. (POMI) and V. Ships UK Ltd./Nordic American Tankers Limited are engaged in manning and shipping business, respectively.
- Respondent Nicolas F. Bobiles was employed by POMI as a pumpman on board the vessel Nordic Vega starting December 24, 2016.
- Employment contract was governed by the Filipino ITF IBF TCC AMOSUP Collective Bargaining Agreement and approved by the Philippine Overseas Employment Administration (POEA).
- Bobiles sustained injury (disc herniation and related spinal conditions) during the performance of his duties resulting in total and permanent disability.
- Administrative and judicial remedies followed including NCMB decision and affirmation/modification by the Court of Appeals (CA).
Medical Facts and Findings
- Bobiles was declared medically fit prior to engagement.
- Injury occurred on January 27, 2017, while servicing equipment on board causing back injury with severe pain and radiating symptoms.
- Medical interventions included prescribed medication, physical therapy, and diagnostic procedures including MRI and EMG-NCV.
- Company-designated physician initially gave a disability assessment (Grade 11) but failed to issue a final and conclusive medical assessment within the prescribed periods under POEA rules.
- Second opinion from Dr. Manuel Fidel M. Magtira confirmed permanent disability preventing return to seafaring duties.
Legal Issues Presented
- Whether attorney's fees are recoverable under Article 111 of the Labor Code or Article 2208 of the Civil Code in disability indemnification cases.
- Whether the lack of a final medical assessment from the company-designated physician negates the need for compulsory referral to a third doctor under POEA Standard Terms and Conditions (POEA-SEC).
- Proper computation and awarding of total permanent disability benefits.
Rules on Attorney’s Fees under Philippine Law
- Article 111 of the Labor Code applies strictly to cases involving unlawful withholding of wages.
- Disability or death indemnification claims are not covered by Article 111.
- Article 2208(2) of the Civil Code allows attorney’s fees only if the plaintiff is compelled to litigate with third persons, not the defendant.
- Article 2208(8) applies solely to indemnity actions under workmen’s compensation and employer’s liabili