Case Summary (G.R. No. 170115)
Antecedents
Parce began his employment with Magsaysay in 1992 and was last engaged as a Senior Electrical Fitter on September 8, 2014. While performing his duties aboard the "Golden Princess," Parce suffered a shoulder injury after lifting heavy objects. Despite initial treatment from the ship doctor and subsequent rehabilitation in the Philippines, his condition deteriorated. Following a series of medical consultations, he was ultimately declared unfit for sea duties by his physician, Dr. Manuel Fidel Magtira.
Medical Evaluations and Treatments
After his medical repatriation on December 9, 2014, Parce underwent multiple therapy sessions but still experienced pain. On April 15, 2015, the company-designated physician at Shiphealth issued a report stating that Parce had reached "maximum medical improvement," but this did not include a clear assessment of his fitness for duty. Subsequently, Dr. Magtira provided a medical opinion declaring Parce permanently unfit for sea service, which led him to request a third medical evaluation.
Legal Proceedings and Labor Arbiter's Decision
Parce filed a complaint before the Labor Arbiter on August 20, 2015, asserting his right to disability benefits under the Philippine Overseas Employment Administration - Standard Employment Contract (POEA-SEC). The Labor Arbiter ruled in favor of Parce on March 29, 2016, noting that the company-designated physician's report lacked a definitive statement regarding his fitness for work, thus deeming his condition as totally and permanently disabled under applicable laws.
Commission on Appeals and Subsequent Decisions
The National Labor Relations Commission (NLRC) upheld the Labor Arbiter's decision on June 30, 2016, stating that the absence of a fitness assessment after the 240-day treatment period rendered him permanently disabled. Berlind's position was further supported by the NLRC, which dismissed Magsaysay's claims of non-compliance by Parce.
Court of Appeals' Ruling
On February 27, 2018, the Court of Appeals reversed the NLRC's ruling, arguing that Parce's failure to immediately challenge his fitness assessment undermined his case. The CA held that the two-month delay between the end of treatment and the filing of his complaint weakened his claims, leading to the dismissal of Parce's case.
Supreme Court's Ruling
The Supreme Court granted Parce's petition for review, focusing on three key issues: the completeness of the final medical report, the necessity of obtaining an independent medical opinion before requesting a third doctor, and the entitlement of Parce to total and permanent disability benefits. The Court emphasized the importance of a conclusive medical assessment and reiterated that failure to provide such by the company-designated physician leads to an automatic assumption of permanent disability by law.
Evaluation of Medical Assessments
The Court determined that the final medical report was insufficient, as it did not clearly state Parce's fitness to return to work.
...continue readingCase Syllabus (G.R. No. 170115)
Case Overview
- Court: Supreme Court of the Philippines
- G.R. No.: 241309
- Decision Date: November 11, 2021
- Petitioner: Ruthgar T. Parce
- Respondents: Magsaysay Maritime Corporation, Princess Cruises Ltd., Sorwin Joy G. Rivera
- Nature of Petition: Petition for Review on Certiorari
- Background: The case concerns a dispute over permanent and total disability benefits after Parce sustained an injury while working as a seafarer.
Antecedents
- Ruthgar T. Parce began his employment with Magsaysay Maritime Agency, Inc. in 1992 and was engaged as a Senior Electrical Fitter for Princess Cruises on September 8, 2014, with a 10-month contract.
- While working on the vessel "Golden Princess," he experienced left shoulder pain after lifting heavy objects and sought medical attention from the ship's doctor.
- After persistent pain, he was declared unfit for work and repatriated to the Philippines on December 9, 2014.
- Upon his return, he consulted with Shiphealth, Inc., the company-designated physician, and underwent extensive physical therapy.
- On April 15, 2015, Shiphealth issued a Final Medical Report stating Parce had reached maximum medical improvement but did not provide a conclusive fitness assessment for sea duties.
Medical History and Findings
- Parce experienced ongoing pain, prompting him to seek a second opinion from Dr. Manuel Fidel Magtira, who ultimately deemed him permanently unfit for sea duties on June 25, 2015.
- Subsequent to this, Parce requested Magsaysay