Case Summary (G.R. No. 217123)
Background of Employment and Initial Medical Condition
On June 1, 2010, Paringit entered into a six-month employment contract with Mid-South Ship and Crew Management, Inc. He was employed on a Panamanian vessel with a specified salary and benefits. Before deployment, Paringit underwent a pre-employment medical examination disclosing his history of high blood pressure, but he was declared fit for duty.
Development of Medical Issues
In October 2011, Paringit began experiencing fatigue and observed blood in his stool. Following a visit to the dock in Las Palmas, Spain, he was admitted to a hospital for severe medical issues, including cardiac insufficiency, severe anemia, and renal dysfunction, leading to his eventual medical repatriation to Manila on February 9, 2012.
Post-Employment Medical Evaluations
After his return to the Philippines, Paringit was admitted to YGEIA Medical Center where further evaluations diagnosed him with multiple cardiovascular conditions, including congestive heart failure. The company-designated physician, Dr. Quetulio, acknowledged his health issues and recommended regular follow-ups and potential open-heart surgery.
Legal Proceedings and Labor Arbiter's Decision
On June 11, 2012, Paringit filed a complaint against the respondents for medical expenses and disability claims. The Labor Arbiter found that Paringit's medical conditions were work-related and granted him a total and permanent disability benefit of $60,000, alongside attorney's fees. This decision was appealed by the respondents to the National Labor Relations Commission.
Findings of the National Labor Relations Commission
On January 31, 2013, the National Labor Relations Commission affirmed Labor Arbiter Savari’s decision, confirming the work-related nature of Paringit’s illnesses. The respondents' motion for reconsideration was denied on March 27, 2013.
Reversal by Court of Appeals
Subsequently, the respondents filed a petition with the Court of Appeals, which on September 11, 2014, reversed the decision of the National Labor Relations Commission. The Court of Appeals argued that Paringit failed to consult a third physician regarding his treatment while highlighting the timing of his complaint filing as premature.
Petition for Review on Certiorari
Paringit sought a review of the Court of Appeals' ruling, arguing the erroneous reliance on the company-designated physician's assessment as well as the presumption of work-relatedness of his illness that he believed entitled him to the disability benefits. In opposition, the respondents maintained that Paringit did not prove his condition was work-related and highlighted his choice for alternative treatment.
Supreme Court's Evaluation
The Supreme Court evaluated whether the Court of Appeals acted with grave abuse of discretion in reversing the labor tribunals&#
...continue readingCase Syllabus (G.R. No. 217123)
Background of the Case
- Oscar M. Paringit (petitioner) filed a Petition for Review on Certiorari against Global Gateway Crewing Services, Inc., Mid-South Ship and Crew Management, Inc., and Captain Simeon Flores (respondents) challenging the decisions of the Court of Appeals.
- The case revolves around Paringit's employment as Chief Mate aboard the vessel Tsavliris Hellas and his subsequent medical conditions and disability claims.
Employment Details
- Paringit entered into a six-month employment contract on June 1, 2010, with a basic monthly salary of $1,700 for a 48-hour work week, plus overtime pay and vacation leave.
- He was declared fit for duty despite disclosing a history of high blood pressure during his pre-employment medical examination.
Medical Condition and Repatriation
- By October 1, 2011, Paringit experienced fatigue and noted blood in his feces.
- On January 13, 2012, he was hospitalized in Spain, diagnosed with "Decompensated cardiac insufficiency, severe anemia, and renal dysfunction." He underwent blood transfusion and was discharged on February 2, 2012.
- After returning to Manila, he continued treatment and was diagnosed with congestive heart failure, hypertensive cardiovascular disease, and valvular heart disease.
Medical Re-evaluation and Recommendations
- Dr. Maria Lourdes A. Quetulio, the company-designated physician, recommended further evaluation and potential