Case Summary (G.R. No. 248774)
Antecedents
On January 13, 2017, Quines filed a Notice to Arbitrate against UPLI and Shell for total and permanent disability benefits, medical reimbursement, and damages. His employment duties as an Able Seaman included physically demanding tasks, which he performed until he began to experience health issues in July 2015.
Petitioner's Version
Quines reported headaches and abdominal pain during a vessel assignment in July 2015, leading to medical repatriation where he was diagnosed with hypertension and other conditions. He returned to work after being declared "fit to work" but began to suffer severe symptoms again in March 2016, resulting in another medical repatriation. Subsequent consultations with company-designated doctors yielded mixed diagnoses, which complexly assessed his fitness for sea duties but failed to undergo a definitive evaluation.
Respondents' Version
The respondents contended that while Quines had pre-existing hypertension, his medical evaluations before and during his employment indicated that he was fit for sea duties. They criticized the claims for disability benefits, asserting that no definitive diagnosis of a serious condition was made by the medical practitioners, thus dismissing the claims of cardiovascular disease.
Ruling of the NCMB-Panel of Voluntary Arbitrators (PVA)
Initially, the PVA ruled in favor of Quines, granting him total and permanent disability benefits based on the conclusion that there was a reasonable connection between his duties and the development of his illness. The PVA noted that while Quines had pre-existing hypertension, the stress and physical demands of his job were substantial contributing factors to his medical deterioration.
Proceedings before the Court of Appeals
Respondents appealed the decision to the Court of Appeals, arguing that Quines was not permanently unfit for duty due to lack of conclusive medical diagnosis for Coronary Heart Disease or Ischemic Heart Disease. The Court eventually reversed the earlier findings, suggesting that his mere status as hypertensive did not preclude his ability to perform as a seafarer.
Core Issue
The principal issue for determination was whether Quines was entitled to total and permanent disability benefits stemming from his alleged work-related medical conditions.
Ruling and Legal Reasoning
The Supreme Court reversed the Court of Appeals’ decision, holding that the illness was indeed work-related or aggravated by Quines’s employment. It emphasized that an employee's pre-existing medical conditions need not exclude them from claiming compens
...continue readingCase Syllabus (G.R. No. 248774)
The Case
- This case involves a Petition for Review on Certiorari (G.R. No. 248774, dated May 12, 2021) challenging the decisions of the Court of Appeals in CA-G.R. SP No. 158565.
- The two contested dispositions are:
- A Decision dated April 24, 2019, which reversed the grant of total and permanent disability benefits to petitioner Kennedy R. Quines.
- A Resolution dated August 9, 2019, that denied Quines' motion for reconsideration.
Antecedents
- On January 13, 2017, Kennedy R. Quines filed a Notice to Arbitrate against United Philippine Lines, Inc. (UPLI) and/or Shell International Trading and Shipping Co. seeking benefits for total and permanent disability, medical reimbursements, and damages.
Petitioner’s Version
- Quines worked as a seafarer for UPLI since 2002, deployed without the need for re-application.
- He signed an employment contract on March 18, 2015, as an "Able Seaman" for Shell Shipping Co. and performed various strenuous duties.
- On July 22, 2015, he reported symptoms including headache and nausea while working. Despite treatment, his condition worsened, leading to his medical repatriation on July 25, 2015.
- Upon returning to the Philippines, he was declared "fit to work" by UPLI's designated physician.
- He continued to experience health issues, including chest pains and dizziness, exacerbated by his work conditions.
- A series of medical consultations led to multiple diagnoses, including hypertension and coronary heart disease, with various medications prescribed.
- Quines alleged that his condition was aggravated by the physical and emoti