Case Summary (G.R. No. 239257)
Background of the Employment
Cayabyab was hired by Ventis Maritime Corporation, a local manning agency, on July 9, 2012, to work aboard the vessel "M/V Dover Highway" for nine months at a monthly salary of USD 422.00. He underwent a Pre-Employment Medical Examination (PEME), which found him fit for duty. As part of his role, Cayabyab reported that he deprived himself of meals to assist crew members, leading to deterioration in his mental health.
Emergence of Psychological Issues
Cayabyab began to exhibit unusual behaviors including erratic sleeping patterns, paranoia, and violent outbursts while onboard. On February 25, 2013, the captain of the vessel informed the employer about his deteriorating condition, leading to his subsequent confinement in a psychiatric clinic in Italy. The attending physician diagnosed him with Occupational Stress Disorder and recommended immediate repatriation due to acute psychosis.
Diagnosis and Disability Assessment
Upon returning to the Philippines, Cayabyab was evaluated by a company-designated physician who concurred in the diagnosis, prescribing medications for schizophrenia. Over a series of follow-ups, he received a Grade 6 disability rating but later sought a second opinion from his personal physician, Dr. Elias D. Adamos, who diagnosed him with total and permanent disability.
Labor Arbiter’s Ruling
On February 21, 2014, the Labor Arbiter ruled in favor of Cayabyab, awarding him total and permanent disability benefits amounting to USD 60,000.00. This decision was prompted by the findings of a debilitating psychological condition due to work-related stress.
NLRC’s Decision
The National Labor Relations Commission (NLRC) later modified this ruling on October 31, 2014, awarding only partial disability benefits corresponding to the Grade 6 rating under the POEA-SEC. This decision was confirmed as final on January 18, 2015, after Cayabyab's motion for reconsideration was denied.
Court of Appeals Ruling
The Court of Appeals (CA) upheld the NLRC's decision, affirming the partial disability classification. The CA emphasized that Cayabyab did not timely seek an evaluation from his personal physician before filing his complaint, which undercut his claims. The CA ordered the petitioners to jointly pay Cayabyab Grade 6 disability benefits in accordance with the provisions of the CBA.
Arguments Presented by Petitioners
The petitioners contended that the CBA had expired prior to Cayabyab’s employment and that the provisions of the POEA-SEC should apply instead. They further argued that the imposition of 6% legal interest on the judgment award was unwarranted since it was not included in Cayabyab's pleadings.
Ruling of the Supreme Court
The Supreme Court held that Cayabyab could not claim benefits under the CBA as he failed to establish the CBA's existence, his employment’s coverage, and t
...continue readingCase Syllabus (G.R. No. 239257)
Case Background
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioners are Ventis Maritime Corporation (VMC) and St. Paul Maritime Corporation (SPMC).
- The respondent is Joseph B. Cayabyab, who was awarded Grade 6 disability benefits based on the Collective Bargaining Agreement (CBA) between the parties.
- The Court of Appeals (CA) issued a Decision on September 25, 2017, and a Resolution on May 4, 2018, which upheld this award and denied the petitioners' Motion for Partial Reconsideration.
Employment Details
- Cayabyab was hired by VMC on July 9, 2012, to work as a wiper on the vessel "M/V Dover Highway" for nine months, with a basic monthly salary of USD 422.00.
- He underwent a Pre-Employment Medical Examination (PEME) and was declared fit for sea duty prior to his deployment.
Incident and Medical Diagnosis
- While performing his duties, Cayabyab reported skipping meals to assist fellow crew members, which contributed to erratic sleeping patterns and poor nutrition.
- His mental health deteriorated, leading to paranoid and violent behavior, requiring restraint by fellow crew members.
- On February 25, 2013, the vessel's master informed VMC of Cayabyab's unusual behavior, prompting medical intervention upon reaching Italy, where he was diagnosed with "Occupational Stress Disorder" and "Acute Psychosis."
Medical Evaluation in the Philippines
- After repatriation, VMC referred Cayabyab to a psychiatrist a