Case Summary (G.R. No. 142773)
Employment Background
Giovannie B. Campanero was employed as a Second Officer by Unitra Maritime Manila, Inc., for its principal VT Maritime, under a contract aligned with the POEA Standard Employment Contract and All Japan Seaman's Union CBA. He began his tenure on April 22, 2014, and subsequently boarded the M/V Mount Akaboshi on May 29, 2014.
Medical Issues and Treatment
Campanero started experiencing health issues shortly after boarding, including weakness in his lower extremities and severe lower back pain. Despite these symptoms, he continued working until he sought medical evaluation while in Japan, where he was diagnosed with a disc hernia and eventually repatriated for further treatment in the Philippines. Upon return, medical findings revealed serious conditions culminating in a spinal arteriovenous malformation. Surgery was performed to correct the issues, but his health continued to decline, leading him to seek further medical opinions due to the withholding of medical assistance from his employer following his surgery.
Findings of Medical Experts
Dr. Francis Pimentel and Dr. Rogelio Catapang provided independent evaluations confirming the severity of Campanero's medical conditions, including paraplegia and sensory deficits, and indicated that his work conditions likely contributed to his injuries. They concluded that his afflictions rendered him permanently unfit for work.
Initial Rulings and Appeal Process
The Labor Arbiter (LA) initially ruled in favor of Campanero, awarding him total permanent disability compensation. However, the NLRC overturned this decision, asserting that Campanero's conditions were not work-related and citing his failure to obtain a second medical opinion before pursuing his labor complaint. The NLRC's ruling was contested in a Petition for Certiorari, which the Court of Appeals granted, reinstating the LA's decision based on the principle that the assessment of the company-designated physician was not final if conflicting medical opinions existed.
Supreme Court's Review and Decision
The Supreme Court highlighted that a seafarer’s illness needs to be work-related and occurred during the employment term to receive benefits. It reiterated that the burden lies on the employer to disprove such illnesses being work-related unless proven otherwise. The Court found that there was a reasonable link between Campanero’s work and his medical conditions. Medical evaluations supported that his duties contributed to the illness, and the failure of the company-designated physician to render a definite assessment within the legal timeframe undermined the employer's position.
...continue readingCase Syllabus (G.R. No. 142773)
Case Overview
- This case involves a Petition for Review on Certiorari filed by Unitra Maritime Manila, Inc., VT Maritime Inc., and/or Capt. Victor M. Villanueva against Giovannie B. Campanero.
- The petition seeks to reverse the rulings of the Court of Appeals (CA), which granted Campanero's claim for permanent and total disability benefits.
Antecedents
Employment Background
- Campanero was hired as a Second Officer by Unitra on April 22, 2014, under a contract compliant with the POEA-Standard Employment Contract and the All Japan Seaman's Union Collective Bargaining Agreement.
- He departed for the M/V Mount Akaboshi on May 29, 2014.
Onset of Medical Condition
- Campanero experienced weakness in his lower extremities and sharp back pain a month into his voyage while lifting heavy provisions.
- He requested an on-shore medical assessment in Japan, leading to a diagnosis of disc hernia and subsequent repatriation.
Medical Treatment and Findings
- Upon returning to the Philippines, he was treated at Manila Doctors Hospital, where his condition worsened, necessitating further medical interventions.
- MRI scans revealed serious conditions, including arteriovenous malformation and a complete spinal cord injury.
Independent Medical Assessment
- Campanero sought the opinion of Dr. Francis Pimentel, who confirmed significant disabilities resulting from his work-related condition.
- Dr. Pimentel's findings indicated that Campanero could not stand or walk without assistance and suffered from severe bowel and bladder incontinence.
Labor Arbiter's Decision
- The Labor Arbiter (LA) ruled in favor of Campanero on March 21, 2016, awarding him permanent