Case Summary (G.R. No. 209582)
Applicable Law
The 1987 Philippine Constitution and relevant provisions from the Labor Code and Rules on Employees' Compensation, particularly Article 198(c)(1) concerning permanent total disability and the corresponding criteria for assessment.
Facts of the Case
On February 18, 2010, Ramoga entered into a contractual employment arrangement to serve as a Deck Trainee on the vessel M/T “SEBAROK SPIRIT,” with a contract duration of eight months, a monthly salary of $264.21, and other employment terms approved by the POEA. Following a pre-employment medical examination, he was deemed fit for sea duty and joined the vessel on April 9, 2010. After six months, he sustained an ankle injury on board, leading to a repatriation on October 4, 2010, and subsequent surgery and rehabilitation in the Philippines.
Labor Arbiter's Ruling
On September 14, 2011, the Labor Arbiter ruled in favor of Ramoga, deeming petitioners liable for providing a total of $60,000 in permanent total disability benefits, along with an illness allowance and attorney’s fees.
NLRC Decision
Upon appeal by the petitioners, the National Labor Relations Commission (NLRC) modified the Labor Arbiter's ruling on March 30, 2012, deleting the sickness allowance but affirming the order to pay the permanent total disability benefits.
Court of Appeals Ruling
The petitioners’ subsequent petition for certiorari was affirmed by the Court of Appeals on May 30, 2013. The CA sustained the NLRC's decision, agreeing with the notion that Ramoga was entitled to his permanent total disability benefits as he was unable to resume work for more than 120 days post-repatriation.
Petitioners' Arguments
The petitioners filed their appeal on the basis that the findings of the CA contradicted factual assessments, specifically alleging that Ramoga had been declared fit to work by the company-designated physician, validly so given the time frame of 186 days from repatriation.
Supreme Court's Ruling
The Supreme Court granted the petition, reversing the CA's earlier decisions. It articulated that questions of law could be raised in a petition for review under Rule 45 but emphasized the exceptions that allowed review of factual findings. The Court highlighted that despite the prolonged timeframe without a definitive return-to-work declaration from the company-designated physician, such declarations from Ramoga's personal physician were not sufficient to establish grounds for his permanent total disability claim.
Criteria for Permanent Total Disability
The Suprem
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Background of the Case
- The case revolves around a petition for review on certiorari filed by Teekay Shipping Philippines, Inc., Teekay Shipping Ltd., and Alex Verchez against Roberto M. Ramoga, Jr.
- The petition challenges the Court of Appeals' decision affirming the National Labor Relations Commission's (NLRC) ruling that held the petitioners liable for permanent total disability benefits owed to the respondent.
Facts of the Case
- On February 18, 2010, Roberto M. Ramoga, Jr. signed a contract for overseas employment with Teekay Shipping Ltd., represented by Teekay Shipping Philippines Inc., as a Deck Trainee on the vessel M/T "Sebarok Spirit."
- His employment contract included specific terms such as a duration of eight months, a monthly salary of $264.21, and a work schedule of 44 hours per week.
- After passing a pre-employment medical examination, Ramoga joined the vessel on April 9, 2010.
- Approximately six months later, he suffered a serious ankle injury while onboard, resulting in a diagnosis of fractures that required surgery.
- Following his repatriation to the Philippines on October 4, 2010, Ramoga underwent a medical evaluation and treatment, which included surgery and rehabilitation.
- The company-designated physician declared him fit for work on April 8, 2011, but Ramoga, dissatisfied, sought a second opinion from his personal physician, who deemed him permanently unfit for sea duties.
Ruling of the Labor Arbiter
- On September 14, 2011, the Labor Arbiter ruled in favor of Ramoga, ordering the petitione