Case Summary (G.R. No. 207511)
Applicable Law
The Philippine Constitution and labor laws applicable in this case hinge on the 1987 Philippine Constitution since the decision date is in 2020, alongside the provisions within the Labor Code and the Philippine Overseas Employment Administration (POEA) Standard Employment Contract of 2000.
Antecedent Facts
San Juan filed a complaint for permanent total disability benefits against PTCI and others, asserting his work-related conditions as a Chief Cook aboard the MV Genmar George T caused hypertension. He underwent a Pre-Employment Medical Examination (PEME) declaring him fit to work, despite a prior condition. After several incidents aboard leading to medical repatriation, subsequent evaluations showed he was fit for duty, though he later sought a second opinion that led to his claim of unfitness for work.
Ruling of the Labor Arbiter
The Labor Arbiter ruled in favor of San Juan, granting him disability benefits based on evidence suggesting his illness was work-related and aggravated by his employment. The Arbiter highlighted the lack of rehiring as indicative of unfitness and disregarded the fitness certification from PTCI's doctors, leading to an award of US$66,000 for permanent disability and unpaid sickness allowance.
Ruling of the National Labor Relations Commission
PTCI appealed the Labor Arbiter's decision to the NLRC, who reversed the decision, asserting San Juan failed to establish a compelling connection between his employment and illness. The NLRC emphasized that he received fit-to-work certifications from company-designated physicians, thus negating his claim for permanent total disability benefits and deemed any ongoing health issues nonoccupational.
Ruling of the Court of Appeals
San Juan's petition to the CA resulted in the reinstatement of the Labor Arbiter's decision, establishing that his condition was disputably presumed work-related. It was asserted that assessments from company-designated physicians were not conclusively binding as the CA noted the absence of evidence from PTCI justifying San Juan's non-rehire, indicative of his permanent disability.
Issues Raised
The petitioners contended that the CA erred in disregarding medical assessments from company-designated physicians, awarding benefits without sufficient evidence of a causal connection, and erroneously granting additional sickness wages.
Supreme Court's Ruling
The Supreme Court ruled in favor of the petitioners, emphasizing that San Juan did not satisfy the criteria for proving permanent total disability, as defined by law, particularly spotlighting the necessity for issuing a
...continue readingCase Syllabus (G.R. No. 207511)
Case Citation
- G.R. No. 207511, October 05, 2020, 887 Phil. 41
- Decided by the Second Division of the Supreme Court of the Philippines
Parties Involved
- Petitioners: Philippine Transmarine Carriers, Inc. (PTCI), Carlos C. Salinas, and/or General Maritime Management LLC
- Respondent: Almario C. San Juan
Procedural History
- The case arises from a Petition for Review on Certiorari challenging the December 11, 2012 Decision of the Court of Appeals (CA) in CA-G.R. SP No. 121634.
- The CA decision overturned the May 26, 2011 Decision and July 15, 2011 Resolution of the National Labor Relations Commission (NLRC) which denied San Juan's claims for permanent total disability benefits, sickness allowance, damages, and attorney's fees.
- The CA denied a motion for reconsideration on June 6, 2013.
Antecedent Facts
- Almario C. San Juan filed a complaint seeking recovery of permanent total disability benefits, medical expenses, damages, and attorney's fees against PTCI, General Maritime Management LLC, and Carlos C. Salinas.
- San Juan was employed as a Chief Cook from February 24, 1992, to May 15, 2008, and then re-hired on August 26, 2009, for a duration of 8 months aboard the MV Genmar George T.
- He had previously declared a medical history of hypertension during his Pre-Employment Medical Examination (PEME) and was cleared for work by company-designated physicians.
- San Juan faced severe health issues while working, leading to multiple collapses and eventual medical attention in India.
- He was repatriated on February 1, 2010, and subsequently treated in the Philippines, where he was certified fit for duty by company physicians bu