Case Summary (G.R. No. 120223)
Antecedent Facts
Pacio underwent a pre-employment medical examination (PEME) before his hiring, revealing a pre-existing condition of hypertension for which he was prescribed medication. Despite being declared fit for sea duty, he acknowledged the risks associated with this pre-existing condition through an Oath of Undertaking, which included provisions regarding the non-compensability of any disabling illness resulting from his hypertension.
On December 10, 2012, Pacio experienced high blood pressure and dizziness while on duty, leading to his repatriation from Romania and subsequent medical evaluation in the Philippines. Medical examinations revealed various health issues including hypertension but concluded that they were not work-related. Despite this finding, the respondents covered the costs of Pacio's medical evaluations until significant time passed without further communication from him, which the respondents interpreted as acceptance of their findings.
Procedural History
Pacio filed a claim for permanent total disability benefits with the National Labor Relations Commission (NLRC), which was initially resolved in his favor by the Executive Labor Arbiter (ELA). The NLRC affirmed this decision, but upon appeal, the Court of Appeals (CA) found grounds to reverse the NLRC's ruling, stating that the previous labor tribunals had disregarded relevant labor laws and contracts.
The Issue
The core issue pertains to whether the CA erred in its reversal of the previous decisions favoring Pacio's claim for disability benefits. Pacio contended that his medical condition, allegedly aggravated by his employment duties, warranted disability compensation. In contrast, the respondents argued that Pacio’s disability was a result of his pre-existing condition rather than any exacerbation from his work.
Arguments of the Parties
Pacio maintained that he was fit for duty at the time of his employment and that his health deteriorated due to the rigorous demands of the job. The respondents countered that Pacio was fully aware of his hypertension and voluntarily accepted the risks, including executing documents asserting that any resulting illness from it would not be compensable. They further contended that Pacio failed to report his medical condition properly and neglected to seek appropriate medical attention following the initial evaluation.
Ruling of the Court
In reviewing the case, the Court highlighted that it generally refrains from reevaluating factual findings unless there are compelling reasons to do so, particularly when lower tribunals’ conclusions conflict with those of the CA. The CA’s ruling was upheld, emphasizing that Pacio inadequately demonstrated that his work duties caused or aggravated his hypertension. Moreover, the absence of a collective bargaining agreement necessitated reliance on the provisions of the POEA Standard Employment Contract (SEC) and the Labor Code, particularly concerning the definition and process for claiming total and permanent disability benefits.
Compliance with Legal Requirements
The Court referenced various statutory p
...continue readingCase Syllabus (G.R. No. 120223)
Overview of the Case
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the Decision dated January 22, 2016, and the Resolution dated July 10, 2016, of the Court of Appeals (CA) in CA-G.R. SP No. 138514.
- The CA's decision reversed the September 30, 2014, ruling of the National Labor Relations Commission (NLRC), which had affirmed the findings of the Executive Labor Arbiter regarding the petitioner's entitlement to permanent total disability benefits.
Antecedent Facts
- On July 4, 2012, Danilo L. Pacio was hired as an Able Seaman by Dohle-Philman Manning Agency for the vessel MV Lady Elisabeth.
- He underwent a pre-employment medical examination (PEME) on June 21, 2012, where he disclosed a history of hypertension since 2011. Despite this, he was declared fit for sea duty after signing an undertaking regarding his condition.
- On December 10, 2012, during his employment, he experienced high blood pressure and dizziness, leading to his referral for medical evaluation in Romania, where he was declared unfit for sea duties and subsequently repatriated.
- Upon returning to the Philippines, he was examined by the agency's appointed physicians, who determined that his hypertension was multifactorial and not work-related.
- After not hearing from the petitioner for nearly a year, the agency received a Notice of Conference from the Philippine Overseas Employment Administration (POEA) in November 2013, signaling the petitioner's intent to claim disability benefits.
- The petitioner filed a claim for permanent total disability benefits, damages, and attorney's fees on December 16, 2013.
Procedural History
- The Exec