Case Summary (G.R. No. 159731)
Employment and Medical Issues
On May 10, 2016, Suelo was hired under a six-month contract, receiving a basic monthly salary and additional pay for overtime and vacation leave. He commenced his duties on May 28, 2016, but on October 29, 2016, he was hospitalized due to severe health issues and was diagnosed with uncontrolled hypertension, leading to his disembarkation from the vessel on medical grounds. He subsequently returned to the Philippines.
Dispute Over Medical Treatment and Benefits
Upon returning to the Philippines on November 4, 2016, Suelo alleged that he was not allowed by the respondent to report to its Manila office and was denied access to a company-designated physician. Instead, the respondent purportedly advised him to seek medical treatment at his own expense, which he later attempted to claim reimbursement for but was denied. He subsequently filed a complaint for permanent and total disability benefits, damages, and attorney’s fees with the National Conciliation and Mediation Board (NCMB).
Respondent's Position
The respondents contended that Suelo had refused treatment with the company-designated physician, thereby forfeiting his right to claim disability benefits. They argued that Suelo was not entitled to sickness allowance or any damages due to the lack of bad faith on their part.
Voluntary Arbitrators' Ruling
The Panel of Voluntary Arbitrators issued a decision on February 18, 2019, dismissing Suelo's claims. They found that evidence showed he sought medical treatment nearly a year after disembarkation and had not submitted proof of incurred medical expenses. The panel concluded that Suelo had, in fact, rejected the offer to see a company-designated physician.
Appeals and Procedural Infirmities
Suelo filed a motion for reconsideration, received on July 12, 2019, which was denied on June 28, 2019. He subsequently filed a petition for review under Rule 43 before the Court of Appeals on August 9, 2019, following a motion for extension on July 22, 2019. The Court of Appeals dismissed the petition citing it was filed two days late and an inaccuracy in the affidavit of service regarding the manner of serving the petition to respondents.
Court of Appeals' Ruling
In its resolution on March 6, 2020, the Court of Appeals maintained that the right to appeal is not inherent and that procedural requirements must be adhered to strictly. The CA found the procedural deficiencies sufficient to render the petition dismissible, thus affirming the finality of the Voluntary Arbitrators' decision.
Supreme Court's Ruling
The Supreme Court ruled in favor of Suelo, finding that the Court of Appeals erred in its dismissal of the Rule 43 Petition solely on procedural grounds. Referencing the principles established in prior cases, the Court clarified that
...continue readingCase Syllabus (G.R. No. 159731)
Case Overview
- The case revolves around a petition for review on certiorari filed by petitioner Virgilio S. Suelo, Jr. against respondents MST Marine Services (Phils.), Inc., Thome Ship Management Pte. Ltd., and Ernando A. Rodio.
- The petition challenges the Resolutions dated September 3, 2019, and March 6, 2020, issued by the Court of Appeals (CA) that dismissed his Rule 43 petition due to procedural infirmities.
Employment Background
- On May 10, 2016, Suelo was hired as Second Engineer by MST Marine Services for a six-month contract aboard the vessel "Janesia Asphalt V."
- His compensation included a basic monthly salary of $1,551.00, overtime pay of $1,155.00, and vacation leave pay of $466.00.
- He commenced his duties on May 28, 2016.
Medical Incident
- On October 29, 2016, Suelo was diagnosed with uncontrolled hypertension at Singapore General Hospital after experiencing severe headache, slurred speech, neck pain, and loss of consciousness.
- He was declared unfit for marine duties and signed off on medical grounds, returning to the Philippines on November 4, 2016.
Reporting to Respondent's Office
- Upon returning, Suelo reported to the Iloilo branch of the respondent on November 7, 2016.
- He claimed that the respondent did not allow him to report to the Manila office and refused to refer him to a company-designated physician.
- The respondent allegedly required him to seek medical treatment at his own expense, which Suelo stated led to a denied reimbursement request.
Legal Action Initiated
- Suelo filed a complaint for permanent and total disability benefits, damages, and attorney's fees with the National Con