Pelayo v. Aarema Shipping
REITERATIONFacts
The Antecedents: Petitioner Bartolome Pelayo was hired as a motorman on board the vessel MT "Newbury" for a ten-month period. He underwent pre-employment medical examinations and was certified fit to work. His contract was extended. Upon his return to the Philippines in December 1995, he filed a complaint for permanent disability benefits, sick wage allowance, medical expenses, moral and exemplary damages, and attorney's fees against the respondents. Petitioner alleged that he developed a heart disease due to strenuous work, experiencing chest pains and difficulty breathing even before his contract expired. He claimed the captain refused a medical check-up until his condition worsened, leading to his diagnosis of a heart ailment in Algeria and subsequent discharge from the vessel. He also presented medical certificates from Nigeria diagnosing him with a heart ailment and recommending an ECG upon arrival in the Philippines. After a post-employment medical examination by respondent Aarema, which allegedly misplaced his Nigerian medical certificate, petitioner sought further medical attention in the Philippines, receiving diagnoses of "chronic stable angina" and "ischemic heart disease, angina pectoris," with recommendations for disability from work as a seaman. Procedural History: The Labor Arbiter dismissed petitioner's complaint, ruling that the alleged heart disease was not contracted during his employment but occurred subsequently. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. The Court of Appeals dismissed petitioner's special civil action for certiorari, holding that he raised factual issues improper for a certiorari petition under Rule 65. The Petition: Petitioner filed a petition for review under Rule 45, assailing the Court of Appeals' decision and resolution. He contended that the Court of Appeals erred in dismissing his petition for certiorari solely on the ground that it is not a trier of facts and in misapplying the provisions of the POEA Standard Employment Contract.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground that it is not a trier of facts. Whether petitioner is entitled to permanent disability benefits, sick wage allowance, and reimbursement for medical expenses under the POEA Standard Employment Contract.
Ruling
The petition is DENIED. The assailed Decision of the Court of Appeals, dated July 18, 2002, as well as its Resolution dated October 18, 2002, in CA-G.R. SP No. 55707, is AFFIRMED.
Ratio Decidendi
On the issue of the Court of Appeals' dismissal of the certiorari petition: The Supreme Court reiterated its ruling in St. Martin Funeral Home v. NLRC, emphasizing that petitions for certiorari from NLRC decisions should be filed with the Court of Appeals. The Court clarified that the Court of Appeals has the power to resolve factual issues in special civil actions for certiorari from NLRC decisions, as provided under Section 9 of Batas Pambansa Blg. 129. However, to expedite justice, the Supreme Court opted to rule on the merits of the case rather than remanding it. On the entitlement to permanent disability benefits: The Supreme Court affirmed the findings of the Labor Arbiter and the NLRC. The Court reiterated the prerequisite for claiming benefits under the POEA Standard Employment Contract: the sickness or injury must have been sustained during the term of the overseas employment contract. Petitioner failed to present evidence proving that his alleged heart ailment was contracted while on board the MT "Newbury." The medical certificates presented were issued in 1996, after the expiration of his contract in December 1995. Petitioner's claim that a Nigerian medical certificate was taken by respondents was deemed self-serving and unsubstantiated, especially in light of the respondents' diligent response to his complaints of fever and chills, which were thoroughly investigated. The Court found no plausible reason why the company would ignore complaints of chest pains and difficulty breathing if they were indeed experienced during employment. The factual findings of labor officials, who are deemed experts in their field, were accorded finality and were binding on the Supreme Court. Therefore, the petitioner failed to establish that his illness occurred during the term of his employment, a condition sine qua non for the award of benefits.
Main Doctrine
For a seafarer to be entitled to permanent disability benefits under the POEA Standard Employment Contract, it must be proven that the sickness or injury was contracted during the term of the overseas employment contract. Medical certificates issued after the expiration of the contract, without proof of the illness being contracted during employment, are insufficient to support a claim for benefits.