Case Summary (G.R. No. 206178)
Factual Background
On October 28, 2009, Perea signed his contract and was deployed on October 31, 2009. He experienced health issues while on board, specifically chest pains and difficulty breathing, which began on May 15, 2010. After a series of medical consultations, including treatment for a welding accident and evaluations for chest pain, he was diagnosed with multiple conditions but ultimately repatriated on June 1, 2010.
Medical Evaluations
Post-repatriation, Perea was seen by company-designated physicians, who performed extensive examinations and tests, including a coronary angiogram, which indicated that he did not have significant coronary artery disease. In contrast, another physician, Dr. Antonio C. Pascual, diagnosed him with uncontrolled hypertension and coronary artery disease based solely on a singular consultation without laboratory corroboration. The opposing medical assessments became central to the dispute over Perea's fitness to work.
Administrative Proceedings
Perea filed a complaint against the respondents for various claims, including underpayment, permanent disability benefits, compensatory and moral damages. The Labor Arbiter dismissed the complaint in February 2011, ruling that the applicable Collective Bargaining Agreement had lapsed by the time Perea was repatriated, and emphasized that the POEA Contract's provisions governed the case.
National Labor Relations Commission Ruling
The National Labor Relations Commission upheld the Labor Arbiter’s decision, emphasizing that Perea's prior undisclosed medical condition barred him from claiming benefits and that the evaluations by company-designated physicians were deemed more credible than those of Dr. Pascual.
Court of Appeals Decision
Perea's appeal was subsequently dismissed by the Court of Appeals, which concluded that to establish a compensable illness under the POEA Contract, substantial evidence needed to support claims of permanent disability, which Perea failed to provide. The appellate court supported the findings of the company-designated physicians, asserting extensive monitoring made their assessments more reliable.
Petition for Review to the Supreme Court
In his subsequent Petition for Review, Perea contested the findings that favored the company-designated physicians, particularly criticizing the National Labor Relations Commission’s reference to a non-issue regarding concealment of pre-existing conditions. He also claimed entitlement to his full sickness allowance, countering the assessment of his alleged unfitness due to hypertension.
Supreme Court Analysis
The Supreme Court resolved several issues, primarily focusing on whether the National Labor Rela
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Case Overview
- This case involves a petition for review filed by Pedro C. Perea, challenging the resolutions of the Court of Appeals affirming the decisions of the National Labor Relations Commission (NLRC) and the Labor Arbiter.
- The case concerns issues of medical fitness for work, disability benefits, and the implications of a potentially concealed pre-existing condition.
Facts of the Case
- On October 28, 2009, Pedro C. Perea entered into a Contract of Employment with Elburg Shipmanagement Philippines, Inc. for a nine-month period as a fitter with a monthly salary of US$698.00.
- He was deployed to work aboard the MV Lemno on October 31, 2009.
- Perea experienced health issues starting May 15, 2010, when he reported difficulty breathing and chest pains, subsequently leading to his request for repatriation due to lingering health concerns.
- Following a welding accident on May 24, 2010, Perea sustained injuries to his left shoulder and fingers.
- He was treated in Turkey, where he was diagnosed with Cubital Tunnel Syndrome and received medical recommendations for rest and rehabilitation.
- Upon repatriation to the Philippines, he underwent further medical evaluations by company-designated physicians, who eventually cleared him of work-related injuries.
Medical Evaluations and Findings
- Initial medical assessments suggested hypertension and the possibility of ischemic heart disease; however, the company-designated physicians later concluded that Perea was medically fit for work.
- Dr. Antonio C. Pascual, an independent cardiologist, diagnosed