Case Summary (G.R. No. 220486)
Timeline of Events
Amores entered into the contract on March 28, 2015, and passed his pre-employment medical examination (PEME). In October 2015, during his employment, he experienced chest pains and was subsequently repatriated on October 18, 2015. Upon returning to the Philippines, Amores reported to the respondent's office and requested a post-employment medical examination but was directed to see his private doctor instead.
Medical Evaluations
On October 20, 2015, Amores consulted his personal physician, Dr. Rogelio M. Ramirez, who prescribed medication and recommended further examinations. Subsequently, on December 15, 2015, the respondent's company-designated physician, Dr. Ramon M. Guzman, evaluated Amores and found him unfit for sea duty due to hypertension and possible ischemic heart disease. Dr. Ana Ma. Luisa Javier later suggested further assessment via a CT Angiogram.
Arbitration and Legal Proceedings
After a grievance meeting failed to resolve the issue, Amores filed a Notice to Arbitrate, claiming that his medical condition was work-related and that he was entitled to full disability benefits among others. The Panel of Voluntary Arbitrators ruled in favor of Amores, declaring him permanently disabled and awarding benefits. However, this decision was reversed by the Court of Appeals, which found Amores's claim to be premature due to his not completing recommended medical tests and the lack of a definitive diagnosis.
Appeals and Arguments
Amores contested the Court of Appeals' decision by highlighting that his repatriation was not due to medical reasons. He argued that the respondent's failure to refer him for a mandatory post-employment examination entitled him to disability benefits by operation of law. The respondent maintained that Amores's claim was premature and that he had not complied with medical advice, which meant there was no basis for a final disability determination.
Court's Consideration of Factual Disputes
The Supreme Court determined that the case turned on factual disputes regarding whether Amores had sought a post-employment medical examination and if respondent's actions could be deemed as refusal to comply with medical advice. However, the Court reiterated its limited function in reviewing facts and emphasized applying the well-established rule that claims must be grounded in substantiated evidence.
Determination of Disability and Work-Relatedness
The Supreme Court examined the procedural aspects of Amores's employment and medical terms. It noted that the medical evaluations performed did not explicitly support a con
...continue readingCase Syllabus (G.R. No. 220486)
Case Background
Parties Involved:
- Petitioner: Solito C. Amores, Jr.
- Respondent: Goldroute Maritime Inc. (on behalf of its principal, Kyowa Kisen Co. Ltd.)
Case Number and Date: G.R. No. 254186, decided on April 17, 2024.
Nature of the Petition:
- This is a Petition for Review on Certiorari to reverse the Decision and Resolution of the Court of Appeals, which overturned the decision of the Panel of Voluntary Arbitrators (PVA) that had granted Amores total and permanent disability benefits.
Factual Background
Employment Contract:
- Amores entered into a contract of employment with Goldroute Maritime Inc. on March 28, 2015, to work as an oiler on the vessel "Kanoura" for nine months and was declared fit for sea duty after a pre-employment medical examination (PEME).
Medical Condition and Repatriation:
- In October 2015, while onboard, Amores began experiencing chest pains and shortness of breath. Prior to reporting these symptoms, he was repatriated on October 18, 2015, at the behest of the ship's Captain without a medical assessment being conducted.
Follow-up Medical Consultations:
- Upon returning to the Philippines, he requested a post-employment medical examination but was advised to see a private doctor. He subsequently consulted Dr. Rogelio M. Ramirez, who prescribed medication and recommended further tests.
Medical Findings:
- On December 15, 2015, upon examination by the company-designated physician, Dr. Ramon M. Guzman, Amores was found unfit for sea duty due to hypertension and potential ischemic heart disease.
- Further evaluation on December 28, 2016, by Dr. Ana Ma. Luisa Javier confirmed hypertensive cardiovascular disease and suggested additional testing.
Procedural History
Initial Claim:
- Amores filed a Notice to Arbitrate after a grievance meeting failed. He argued that his illness was work-related and sought total disability benefits, sick