Case Summary (G.R. No. 223035)
Factual Background
Petitioner Reynaldo Sunit was hired by OSM Maritime Services, Inc. as an Able Body Seaman on June 18, 2012, with a three-month employment contract at a monthly salary of $689. During his service, he suffered a significant injury—specifically, a broken right femur—due to a fall from the vessel. Post-injury, he received medical attention in the Netherlands and upon returning to Manila underwent further treatment, ultimately being evaluated by various medical professionals regarding his disability status.
Medical Assessments and Disputes
The initial assessment by the company-designated physician provided Sunit a Grade 10 interim disability on January 13, 2013, which implied an irregular union of his fractured thigh. Unsatisfied with this evaluation, Sunit sought a second opinion from Dr. Garduce, who suggested a Grade 3 disability. A subsequent assessment by a third medical professional, Dr. Bathan, awarded him a Grade 9 disability but also indicated he was "not yet fit to work" and required further rehabilitation. This disparity in assessments formed the crux of the arguments regarding the degree of Sunit's disability.
Labor Arbiter's Decision
The Labor Arbiter (LA), upon examining the conflicting medical opinions, awarded Sunit disability benefits corresponding to a Grade 9 disability, amounting to $13,060. The decision hinged on the conclusion that the assessment was valid under the applicable provisions of the POEA-SEC, advocating for a structured approach in evaluating compensation based on the medical findings.
National Labor Relations Commission Ruling
Sunit appealed the LA’s decision to the National Labor Relations Commission (NLRC), which rendered a judgment on August 29, 2014, changing the awarded benefits to a total and permanent disability compensation of $150,000. The NLRC reasoned that the lapse of 240 days from repatriation without a conclusive assessment from the company-designated doctor warranted the classification of Sunit's condition as permanently and totally disabled.
Court of Appeals Decision
Respondents contested the NLRC's ruling through a certiorari petition to the Court of Appeals (CA), resulting in the CA’s June 10, 2015 decision which reinstated the LA’s findings. The CA determined that the 240-day assessment period was applicable only to the company-designated physician and emphasized that the third-party physician's findings, although valid, did not hold the same temporal constraints since they were sought at the parties' discretion post-injury.
Legal Issues Presented
The primary issues were centered on the appropriate disability grading awarded to Sunit, where he questioned the validity of the Grade 9 assessment by the CA and raised allegations regarding the presence of bad faith from the respondents in settling his claims for damages and attorney’s fees.
Court's Ruling
The Supreme Court ruled in favor of Sunit, determining that he was entitled to total and permanent disability benefits. The Court redefined key definitions of "permanent" and "total" disability, asserting that Sunit's inability to return to work for more than 240 days rendered him perman
...continue readingCase Syllabus (G.R. No. 223035)
Nature of the Case
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioner Reynaldo Sunit challenges the June 10, 2015 Decision and February 10, 2016 Resolution of the Court of Appeals (CA).
- The CA's decision reversed and set aside the August 29, 2014 Decision of the National Labor Relations Commission (NLRC).
Factual Antecedents
- Petitioner was hired by OSM Maritime to work as an Able Body Seaman on the vessel Skandi Texel with a contract lasting three months at a monthly salary of $689.
- The employment contract incorporated the 2010 Philippine Overseas Employment Agency Standard Employment Contract (POEA-SEC) and the NIS AMOSUP Collective Bargaining Agreement (CBA).
- On June 18, 2012, Sunit fell approximately 4.5 meters from the vessel's tank, resulting in a broken right femur, requiring immediate medical attention in the Netherlands and subsequent repatriation.
- Upon returning to Manila on October 6, 2012, he underwent a post-employment medical examination revealing a fractured femur.
- The company-designated physician issued a Medical Report on January 13, 2013, assigning an interim disability grade of 10, indicating an irregular union of the fracture.
- Dissatisfied with this assessment, Sunit consulted Dr. Venancio P. Garduce, who recommended a disability grade of 3.
- After further treatment, the company doctor assessed Sunit with a final disability grade of 10 on February 15, 2013.
- Respondents offered disability benefits of $30,225 based on the Grade 10 assessment, which Sunit refused, claiming entitlement to $150,000 based on the POEA-SEC and NIS AMOSUP CBA.
- A third medical opinion was sought from Dr. Lyndon L. Bathan, who assigned a Grade 9 disability and stated