Anuat v. Pacific Ocean Manning, Inc.
REITERATIONFacts
The Antecedents: Petitioner Mon C. Anuat (Anuat) was hired by respondent Pacific Ocean Manning, Inc. (Pacific) as an able seaman. He sustained injuries to his neck, back, and left knee during unloading operations in Venezuela. He was medically repatriated to the Philippines and underwent treatment and examination by Pacific's company-designated physician, Dr. Nicomedes Cruz. MRI results revealed spinal and left knee injuries. Dr. Cruz recommended surgery for the left knee and advised Anuat to return on September 30, 2011. Anuat did not return and instead filed a complaint for total and permanent disability benefits on October 26, 2011. Procedural History: The Labor Arbiter granted Anuat total and permanent disability benefits. The National Labor Relations Commission (NLRC) modified the decision, awarding higher disability benefits and attorney's fees, and dismissed Pacific's appeal for being unperfected. The Court of Appeals (CA) granted Pacific's petition for certiorari, vacated the NLRC resolutions, and dismissed Anuat's complaint, ruling that his cause of action for total and permanent disability had not yet accrued. The Petition: Anuat seeks review of the CA decision, raising issues on his entitlement to total and permanent disability benefits and attorney's fees.
Issue(s)
Whether Anuat is entitled to total and permanent disability benefits under the Labor Code. Whether Anuat is entitled to attorney's fees.
Ruling
The Supreme Court affirmed the Court of Appeals' decision denying Anuat's claim for total and permanent disability benefits. However, the Court granted partial and permanent disability benefits of "Grade 10" and "Grade 11" in accordance with the collective bargaining agreement (CBA) and Pacific's admission, ordering Pacific to pay Anuat US$31,257.00. The claim for attorney's fees was denied.
Ratio Decidendi
On the entitlement to total and permanent disability benefits: The Court ruled that Anuat's cause of action for total and permanent disability benefits had not yet accrued. Under Presidential Decree No. 442 (Labor Code) and its implementing rules, temporary total disability only becomes permanent if it lasts continuously for more than 120 days, which can be extended to 240 days if further medical treatment is required. In this case, Anuat filed his claim on October 26, 2011, which was 160 days from the onset of his injury. At that time, he was still undergoing medical treatment, and the 240-day extended period had not yet lapsed. The company-designated physician had advised him to return for further examination on September 30, 2011, but he failed to do so. Therefore, his temporary total disability had not yet been declared permanent, and his cause of action had not ripened, consistent with the ruling in Gomez v. Crossworld Marine Services, Inc. and C.F. Sharp Crew Management, Inc. v. Taok. On the entitlement to attorney's fees: The Court denied Anuat's claim for attorney's fees. The general rule is that attorney's fees are not awarded unless there is a showing of bad faith. In this case, Anuat did not present sufficient evidence of bad faith on the part of Pacific. Pacific was still providing medical care to Anuat, and it was Anuat who failed to return for his scheduled medical examination. Therefore, Pacific was not remiss in its obligations, and Anuat's premature filing of his claim did not constitute bad faith on the part of the employer.
Main Doctrine
A seafarer's cause of action for total and permanent disability benefits does not accrue until the lapse of the 240-day extended medical treatment period, or until the company-designated physician declares fitness to work or permanent disability. Partial and permanent disability benefits are payable based on the disability grading determined by the company-designated physician, as stipulated in the collective bargaining agreement.