NFD International Manning, Agents, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Complainant Romel Bearneza was hired as a wiper on board M/S Wilnina with a monthly salary of US$413.00 for a ten-month contract commencing February 15, 1985. On November 8, 1985, while on board, he was mauled by four unidentified persons, diagnosed with contusion on the face and lumbar region with epilepsy, and later with suspected epilepsy. He was declared unfit for work and repatriated. On February 3, 1986, his attending physician at St. Luke's Hospital declared him fit for work. However, from September 25, 1986, to January 1, 1987, he was confined for 98 days at the Western Visayas Medical Center, where he was diagnosed with "Schizophreniform Disorder," which was deemed a total permanent disability, entitling him to US$30,000.00 in insurance benefits. Procedural History: The Philippine Overseas Employment Agency (POEA) denied Romel Bearneza's claim for permanent total disability benefits. The National Labor Relations Commission (NLRC), Second Division, reversed the POEA's decision, granting the benefits. Petitioner NFD International Manning Agents, Inc. filed a petition for certiorari with the Supreme Court, seeking to nullify the NLRC's decision. The Petition: Petitioner contends that the NLRC acted with grave abuse of discretion, arguing that the ailment was acquired after the contract's expiration and after the private respondent was declared fit to work. Petitioner asserts that the diagnosis of "Schizophreniform Disorder" occurred significantly after the fitness declaration and that epilepsy does not cause schizophrenia.
Issue(s)
Whether the NLRC committed grave abuse of discretion amounting to lack or excess of jurisdiction in awarding permanent total disability benefits to the private respondent. Whether the private respondent's "Schizophreniform Disorder" was acquired after the expiration of his contract and after he was declared fit for work. Whether there is a causal connection between the mauling incident, the resulting epilepsy, and the subsequent "Schizophreniform Disorder."
Ruling
The petition is utterly bereft of merit and is DISMISSED. The NLRC did not commit grave abuse of discretion. The award of permanent total disability benefits to the private respondent is affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion and the award of permanent total disability benefits: The Supreme Court held that the NLRC did not commit grave abuse of discretion. The Court found that the NLRC's conclusion was supported by substantial evidence, even though it differed from the POEA's findings. The NLRC correctly considered the medical declaration of fitness for work in February 1986 as inconclusive, particularly because it was not a result of a mental examination. Furthermore, the petitioner failed to present sufficient medical evidence to negate the possibility that epilepsy could develop into schizophrenia, or that the mauling incident, contusions, epilepsy, and subsequent schizophrenia were not causally linked to the private respondent's permanent total disability. The Court reiterated that strict rules of evidence are not applicable in claims for compensation and disability benefits, and probability, not the ultimate degree of certainty, is the test of proof in such proceedings. Therefore, the NLRC acted within its sound discretion in awarding the benefits. On whether the ailment was acquired after the contract's expiration and fitness declaration: The Court found that the petitioner's argument that the ailment was acquired after the contract's expiration and fitness declaration was not persuasive. The private respondent's contract could no longer be performed due to the mauling incident on board the vessel, which resulted in contusions and epilepsy. While he was declared fit to work on February 3, 1986, no mental examination was shown to have been conducted during this physical examination. The subsequent diagnosis of "Schizophreniform Disorder" on September 25, 1986, was considered by the NLRC as a development from the initial condition, especially given medical opinions suggesting that psychiatric problems are common in patients with epilepsy and that head trauma can be a possible cause of epilepsy. The Court emphasized that the private respondent was unable to resume work since the mauling incident, and the subsequent diagnosis confirmed his permanent total disability. On the causal connection between the mauling, epilepsy, and schizophrenia: The Supreme Court agreed with the private respondent that the finding of epilepsy does not preclude its development into "Schizophreniform Disorder," which constitutes permanent total disability. The Court considered the medical opinion of Dr. Rene Gigato Seyan, who cited medical literature indicating that psychiatric problems are common in patients with epilepsy and that head trauma, such as from mauling, could be a possible cause of epilepsy. The Court concluded that the evidence showed the private respondent was mauled during his employment, which led to epilepsy and subsequently developed into "Schizophreniform Disorder," considered a total permanent disability. The Court reiterated the principle that in disability compensation, it is the incapacity to work and the impairment of earning capacity that are compensated, not merely the injury itself. The petitioner failed to negate the causal confluence of these events, which led to the private respondent's permanent total disability.
Main Doctrine
The NLRC did not commit grave abuse of discretion in awarding permanent total disability benefits to a seaman, finding a causal link between the mauling incident during employment, subsequent epilepsy, and the development of Schizophreniform Disorder, despite a prior declaration of fitness for work, as strict rules of evidence do not apply in compensation claims and probability is the test of proof.