Case Summary (G.R. No. 247778)
Antecedents
Palada was hired on May 6, 2016, and deployed on May 20, 2016, for an eight-month term on the vessel MIV Eurocargo Venezia, under an ITALIAN Collective Bargaining Agreement (CBA) for non-domestic seafarers. On July 11, 2016, he was involved in an accident on the vessel, resulting in injuries to his back. After initially receiving treatment, he was repatriated to the Philippines on July 18, 2016. The company-designated physician, Dr. Rodolfo P. Bergonio, initially assessed his condition but later declared him fit to work, which Palada contested, leading to further medical evaluations.
Rulings of the Panel of Voluntary Arbitrators
In a decision dated April 2, 2018, the Panel of Voluntary Arbitrators ruled in favor of Palada, determining that he was entitled to total and permanent disability benefits amounting to US$60,000, as the company-designated physician did not provide a conclusive assessment of his fitness to work within the stipulated time frames. The Arbitrators rejected the appropriateness of the fit-to-work assessment, noting that Palada had not been re-deployed and thus deemed him totally disabled.
Ruling of the Court of Appeals
The Court of Appeals (CA) subsequently reversed the decision of the Arbitrators in a ruling dated February 18, 2019, asserting that the Grade 11 disability rating given by the company’s physician was a sufficient assessment of Palada's condition. The CA held that the assessments of the company-designated physician should take precedence over those of Palada’s private physician, Dr. Manuel Fidel Magtira, as there was no third doctor to resolve the conflicting medical opinions.
Issues Raised by the Petitioner
Palada raised several legal issues, primarily arguing that the CA’s decision was an error, particularly regarding the validity of the assessments made by the company-designated physician. He contended that the ratings were not final and that he was, in fact, permanently disabled due to the absence of a definitive assessment of his condition within the appropriate periods.
Court's Ruling
The Supreme Court found merit in Palada’s petition, emphasizing that to qualify for total and permanent disability benefits, there must be adherence to the legal standards provided under the Labor Code and the employment contract. The Court highlighted that the medical assessments provided were neither complete nor definitive. The initial Grad
...continue readingCase Syllabus (G.R. No. 247778)
Background of the Case
- The case involves a Petition for Review on Certiorari filed by Jerome D. Palada against Crossworld Marine Services, Inc. and its foreign principal, Kapal (Cyprus) Limited.
- The key legal question centers around the interpretation of disability benefits awarded to Palada following an accident while employed as a seaman.
- The Court of Appeals' decision, dated February 18, 2019, reversed earlier rulings by the Panel of Voluntary Arbitrators which had favored Palada.
- The initial ruling by the Voluntary Arbitrators awarded Palada US$60,000.00 in total and permanent disability benefits due to his injuries sustained at work.
Factual Antecedents
- Palada was hired as an ordinary seaman on May 6, 2016, with an eight-month contract governed by the ITALIAN CBA for NON DOMS.
- He was deployed on May 20, 2016, and sustained injuries on July 11, 2016, after being hit by a moving vehicle on the vessel.
- Medical evaluation in Malta diagnosed him with "trauma successive dorsal contusion of lumbo sacral spine," leading to his repatriation on July 18, 2016.
- Treatment by the company-designated physician, Dr. Rodolfo P. Bergonio, continued from July to October 2016, leading to a Grade 11 disability rating due to persistent pain.
- Palada later sought a second opinion from Dr. Manuel Fidel M. Magtira, who assessed him as "permanently UNFIT" to resume sea duties.
- Following a failed amicable resolution, Palada filed for disability benefits with the National Conciliation and Mediation Board (NCMB).
Panel of Voluntary Arbitrators' Ruling
- The Panel of Voluntary Arbitrators r