Title
Supreme Court
Varorient Shipping Co., Inc. vs. Flores
Case
G.R. No. 161934
Decision Date
Oct 6, 2010
Seafarer Flores, diagnosed with work-related sciatic neuralgia, sought medical reimbursement and sickness wages. Despite a quitclaim, the Supreme Court ruled in his favor, affirming employer liability under the POEA contract for unpaid wages and medical expenses due to inadequate treatment.

Case Summary (G.R. No. 208093)

Applicable Law

The decision is based on the 1987 Philippine Constitution alongside relevant provisions from the Philippine Overseas Employment Administration (POEA) Standard Employment Contract and Labor Code.

Employment Contract and Medical Treatment

Respondent was employed as a Chief Officer under a contract approved by the POEA, with a total monthly salary of US$2,100. Upon reporting for duty, he experienced severe pain in his right foot, which was diagnosed as sciatic neuralgia requiring treatment, leading to his repatriation for further medical care.

Medical Findings

Upon his repatriation, respondent underwent further medical examinations, revealing a large disc herniation at the L5-S1 level with nerve root compression, necessitating physical therapy and potentially surgical intervention.

Legal Complaints and Claims

Respondent filed a complaint against petitioners for failing to provide adequate medical treatment, claiming sickness wages and disability benefits after incurring significant medical expenses. He asserted that petitioners acted with bad faith in denying continued treatment and payment.

Labor Arbiter's Ruling

The Labor Arbiter dismissed respondent's claims stating that petitioners had complied with their obligations, including declaring respondent fit for work, and deemed the Receipt and Quitclaim signed by respondent valid evidence of payment.

NLRC Decision

The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, stating that the petitioners had not fully complied with their obligation to provide continuous medical treatment. The NLRC ordered petitioners to pay sickness wages and reimbursement of medical expenses, awarding a net amount of US$3,790 after deducting prior payments.

Court of Appeals Confirmation

The Court of Appeals upheld the NLRC's decision with modifications, reiterating that petitioners were responsible for covering the cost of sickness wages for 120 days, reflecting the compulsory entitlements under the Standard Employment Contract.

Arguments and Rulings on Payment Claims

Petitioners argued against the presence of ongoing financial obligations, claiming prior cash advances. However, evidence was found contradicting this, as the vouchers lacked formal documentation. The court upheld that the petitioners had an obligation to provide medical treatment and wage compensation.

Validity of the Qui

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