INC Navigation Co. Philippines, Inc. v. Rosales
REITERATIONFacts
The Antecedents: Benjamin Rosales (Rosales) was hired as Chief Cook for a vessel owned by INC Shipmanagement, Inc. (INC) and its foreign principal. While on board, Rosales experienced severe chest pain and breathing difficulties, leading to his examination and treatment in the USA. Upon repatriation, he was diagnosed with acute myocardial infarction secondary to coronary artery disease, hypertension, and diabetes mellitus. The company-designated physician, Dr. Nicomedes G. Cruz, assessed him with a Grade 7 partial permanent disability. However, a private cardiologist, Dr. Efren R. Vicaldo, assessed Rosales with a Grade 1 permanent total disability, deeming his illness work-related and rendering him unfit for sea duty. Procedural History: Rosales filed a complaint for permanent total disability benefits, which was initially granted by the Labor Arbiter (LA). The National Labor Relations Commission (NLRC) initially affirmed the LA's decision but later reversed it, awarding only partial disability benefits based on Dr. Cruz's assessment. Rosales filed a petition for certiorari with the Court of Appeals (CA), which reinstated the LA's decision, finding Rosales entitled to permanent total disability benefits. INC then filed the present petition with the Supreme Court. The Petition: INC argued that the CA erred in finding grave abuse of discretion on the part of the NLRC, asserting that disability is measured by gradings, not by the number of days of inability to work, and that the company-designated physician's findings should prevail in case of conflicting assessments.
Issue(s)
Whether Rosales is entitled to full disability compensation benefits because he was unable to work for one hundred twenty (120) days. Whether the CA erred in finding grave abuse of discretion on the part of the NLRC in favoring the findings of Rosales’ physicians over that of the company-designated physician.
Ruling
The Supreme Court granted the petition, set aside the assailed decision and resolution of the Court of Appeals, and dismissed the complaint.
Ratio Decidendi
On the entitlement to full disability compensation benefits based on the 120-day period: The Court clarified that while a seafarer is entitled to temporary total disability benefits during the 120-day treatment period, this does not automatically translate to permanent total disability benefits. Permanent disability transpires when the inability to work continues beyond 120 days, but the extent of disability (total or partial) is determined by the disability grading given by the doctor, not solely by the duration of inability to work. The Court emphasized that the impairment of earning capacity is the basis for compensation, and this is assessed through the doctor's grading, which ranges from Grade 1 to Grade 14, with only Grade 1 considered total and permanent under the POEA-SEC. Confusing the concepts of permanent and total disability by merely counting days of inability to work could lead to abuse by delaying treatment. On the CA's finding of grave abuse of discretion and the prevailing physician's assessment: The Court found that the CA gravely abused its discretion by disregarding the governing contract between the parties, specifically the provisions of the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC). The POEA-SEC mandates that in case of conflicting medical assessments between the company-designated physician and the seafarer's physician, a third doctor should be agreed upon by both parties, and the third doctor's decision shall be final and binding. Rosales failed to signify his intent to submit the disputed assessment to a third doctor, thus breaching the mandatory procedure outlined in the POEA-SEC. Consequently, the assessment of the company-designated physician, Dr. Cruz, should prevail. The Court noted that Dr. Cruz had thoroughly examined and treated Rosales for an extended period, making his assessment more credible than that of Dr. Vicaldo, who attended to Rosales only once.
Main Doctrine
The assessment of the company-designated physician on the degree of disability of a seafarer prevails over the assessment of a private physician, unless the seafarer signifies his intent to refer the conflicting assessments to a third doctor, whose decision shall be final and binding. The mere lapse of 120 days does not automatically entitle a seafarer to permanent total disability benefits; the extent of disability is determined by the doctor's grading based on the resulting incapacity to work and earn wages.