Case Summary (G.R. No. 159887)
Employment Contract and Incident
On November 27, 1997, Remigio entered into a contract of employment with Respondent Agency, which represented Respondent Principal. This contract outlined that standard employment conditions for seafarers set forth by the Philippine Overseas Employment Administration (POEA) would apply. Remigio worked as a Musician II on the vessel "SS Enchanted Isle" and began his employment after passing a pre-employment medical examination. On March 16, 1998, while in Cancun, Mexico, he experienced severe chest pains, leading to a series of medical evaluations culminating in a triple coronary artery bypass surgery on April 2, 1998.
Medical Treatment and Employment Status
Remigio was hospitalized for an extended period and, upon recovery, was ultimately deemed “not fit for sea duty” by his cardiologist. After being repatriated to the Philippines on April 23, 1998, he was referred for further evaluation by the agency’s designated medical facility. He later formally demanded payment for unpaid wages, sickness allowance, and permanent total disability benefits, which the Respondent declined.
Proceedings Before Labor Arbiter and NLRC
Remigio subsequently filed a complaint, and the Labor Arbiter awarded him US$3,400.00 in sickness allowance but denied the claim for disability benefits, citing that the 1996 POEA Standard Employment Contract did not classify his cardiac issues as compensable. The NLRC affirmed the Labor Arbiter's decision in full, leading Remigio to appeal to the Court of Appeals. The appellate court also upheld the prior decisions, primarily finding insufficient evidence to establish that Remigio's heart condition was work-related and directly caused a permanent disability.
Issue of Permanent Total Disability Benefits
The Supreme Court highlighted that the key question was whether Remigio was entitled to permanent total disability benefits. The Court noted that while the Labor Arbiter and the CA found that the heart ailment was not listed as compensable under the 1996 POEA SEC, they failed to recognize the non-exclusivity of the schedule. The Court determined that the illness need not be categorized as an occupational disease for Remigio to be entitled to benefits under the contract.
Application of Labor Code Concepts
In assessing the situation, the Court applied principles from the Labor Code pertaining to disability benefits. It elaborated on the standard that recognizes permanent total disability as resulting from an inability to perform gainful employment beyond 120 days. The discussion clarified that a disability is evaluated on the basis of the individual’s earning capacity rather than solely on medical documentation of physical inability.
Court Findings and Conclusion
The Supreme Court found Remigio suffered from permanent total disability because medical evaluations indicated he was unfit for his specific job as a drummer for a significant length of time (11 to 13 months). The Court
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Case Overview
- This case involves a petition for review on certiorari from Bernardo Remigio, who seeks to reverse the decision of the Court of Appeals (CA) affirming the National Labor Relations Commission’s (NLRC) ruling.
- The NLRC had awarded Remigio a sickness allowance of US$3,400.00 but denied his claim for permanent total disability benefits.
- The petition was resolved on April 12, 2006, by the Supreme Court's Second Division.
Factual Background
- Bernardo Remigio entered a Contract of Employment with C.F. Sharp Crew Management, Inc. on November 27, 1997, to serve as Musician II on the SS "Enchanted Isle" for ten months.
- His contract was governed by the standard employment terms set forth in the 1996 POEA SEC.
- After passing a pre-employment medical examination, he commenced work in December 1997.
- On March 16, 1998, while in Cancun, Mexico, Remigio experienced severe chest pain and shortness of breath, which led to hospitalization and a series of medical evaluations including a coronary bypass surgery on April 2, 1998.
- He was repatriated to Manila on April 23, 1998, after being deemed unfit for sea duty.
Procedural History
- Following his repatriation, Remigio demanded payment for unpaid wages, sickness allowance, and permanent total disability benefits, which was refused by his employers.
- On November 12, 1998, he filed a complaint for these claims.
- The Labor Arbiter awarded him US$3,400.00 for sickness allowance but