Case Summary (G.R. No. 219824-25)
Factual Background
Wilfredo T. de Leon was employed by Scanmar Maritime Services, Inc. as a seafarer, primarily on vessels managed by Crown Shipmanagement, Inc. He was repatriated on September 13, 2005, after fulfilling a nine-month contract. Following his repatriation, de Leon sought disability benefits, alleging that he had suffered from L5-S1 radiculopathy due to his work conditions. His claim was supported by several medical documents. Notably, prior to his next deployment, he was noted to have dragged his right leg during a pre-employment medical examination, prompting further medical evaluation, but he subsequently failed to follow up.
Procedural History
After two years of silence, de Leon filed a complaint with the Labor Arbiter (LA) seeking disability benefits and attorney’s fees. The LA ruled in favor of de Leon, awarding him USD 60,000 in disability benefits and attorney’s fees, asserting that the absence of a recorded incident at the time of disembarkation implied that his disability must have arisen during his prolonged service. Petitioners appealed to the National Labor Relations Commission (NLRC), which upheld the LA's decision. The matter escalated to the Court of Appeals, which also ruled in favor of de Leon, leading to the present petition before the Supreme Court.
Issues Raised
The petitioners raised several issues, contesting the validity of de Leon’s claims, specifically that he failed to: (1) prove that his illness was acquired during employment; and (2) comply with the mandatory post-employment examination requirement under the POEA Contract. They also challenged the award of attorney’s fees granted to de Leon.
Supreme Court Ruling
The Court emphasized that for disability benefits to be granted under the POEA Contract, three conditions must be satisfied: (1) the seafarer must undergo a post-employment medical examination within three days of disembarkation; (2) the injury must happen during the employment duration; and (3) the injury must be work-related. The Court noted de Leon’s failure to comply with the post-employment examination requirement and dismissed the justification that he was not medically repatriated. It reiterated that the requirement applies uniformly to all seafarers, regardless of circumstances.
Analysis of Evidence
The Supreme Court found that de Leon did not provide adequate evidence to establish that his injury occurred during the term of his employment. Notably, medical documentation was generated significantly after disembarkation, and he failed to report any illness during his service, as corroborated by the vessel’s ch
...continue readingCase Syllabus (G.R. No. 219824-25)
Case Overview
- The case revolves around a Petition for Review on Certiorari filed by Scanmar Maritime Services, Inc., Crown Shipmanagement Inc., and Victorio Q. Esta against Wilfredo T. De Leon.
- The petitioners contested the Decision and Resolution of the Court of Appeals (CA) which upheld the rulings of the National Labor Relations Commission (NLRC) and the Labor Arbiter (LA) that granted De Leon disability benefits and attorney's fees.
Background of the Case
- Wilfredo T. De Leon worked as a seafarer for Scanmar Maritime Services, Inc. aboard Crown Shipmanagement, Inc. vessels.
- He completed his contract on September 13, 2005, and reported for a pre-employment medical examination on November 17, 2005, where a neurologist was consulted due to observed leg dragging.
- Two years later, in December 2007, De Leon requested disability benefits of USD 60,000, which went unanswered, leading him to file a complaint with the LA for benefits and fees.
Complaint Details
- De Leon claimed that during his last deployment, he experienced significant health issues, including abdominal pain and blood in his stool.
- He provided medical evidence of L5-S1 radiculopathy, including:
- An Electrodiagnostic Laboratory Report (October 5, 2005).
- A Medical Certification from Seamen's Hospital (November 21, 2005) declaring him unfit for work.
- An MRI report (December 7, 2005) indicating mild central canal stenosis.
- A Medical Certification from Plaridel Country Hospital (October 6,