Dohle Philman Manning Agency v. Doble
REITERATIONFacts
The Antecedents: Julius Rey Quinal Doble, a Filipino seafarer, was employed as an Ordinary Seaman by DOHLE (IOM) Ltd., through its manning agent DOHLE Philman Manning Agency, Inc. During his contract, Doble sustained two injuries: first, a twisted right foot while preparing to heave a mooring line, and second, hand injuries from a tug line incident. He was repatriated to the Philippines on April 11, 2013, and subsequently diagnosed with a right ankle sprain, bilateral carpal tunnel syndrome, and a right knee osteochondral defect. After undergoing surgery and physical therapy, the company-designated physician initially issued an interim disability grade and later declared him fit to work on November 8, 2013. Dissatisfied, Doble consulted his own physician, who declared him permanently disabled and unfit to resume his usual sea duties. When the employer refused his claim for disability benefits, Doble filed a case. Procedural History: The Labor Arbiter (LA) ruled in favor of Doble, finding him permanently and totally disabled and ordering the payment of US$90,882.00 plus attorney's fees. The National Labor Relations Commission (NLRC) affirmed the LA's decision in its entirety. The petitioners then filed a Petition for Certiorari with the Court of Appeals (CA), which affirmed the NLRC decision but modified the basis of the award to US$60,000.00 in permanent total disability benefits plus attorney's fees, citing the POEA-SEC instead of the CBA. Both parties moved for reconsideration, which the CA denied. These consolidated petitions for review on certiorari followed. The Petition: Both parties filed Petitions for Review on Certiorari under Rule 45 of the Rules of Court. The petitioners (DOHLE) argue that the CA erred in awarding disability benefits, as the company-designated physician cleared Doble for work, and the CA disregarded the mandatory procedure of referring conflicting medical assessments to a third doctor. They also contend that the CA improperly relied on the 120-day rule for disability assessment and erred in awarding attorney's fees. Doble, in his petition, argues that the CA erred in modifying the decision by awarding benefits based on the POEA-SEC instead of the more favorable Collective Bargaining Agreement (CBA).
Issue(s)
Whether or not the respondent is fit to work and thus entitled to disability benefits. Whether or not the basis of the award of damages should be the CBA and not the POEA-SEC. Whether or not the respondent is entitled to attorney's fees.
Ruling
The Supreme Court granted the petition in G.R. No. 223730 and dismissed the petition in G.R. No. 223782. The Decision of the Court of Appeals was reversed and set aside, and a new judgment was rendered dismissing the Complaint.
Ratio Decidendi
On the issue of whether the respondent is fit to work and thus entitled to disability benefits: The Court found merit in the petitioners' contentions. It reiterated that the referral to a third doctor is a mandatory procedure when there are conflicting medical assessments between the company-designated physician and the seafarer's physician. In this case, the respondent was declared fit to work by the company-designated physician, while his personal physician declared him permanently disabled. However, the respondent failed to demand a referral to a third doctor as required by Section 20 of the POEA-SEC. The Court emphasized that failure to abide by this mandatory procedure renders the assessment of the company-designated physician final and binding. Therefore, the respondent was considered fit to work and not entitled to disability benefits. On the issue of whether the basis of the award of damages should be the CBA and not the POEA-SEC: This issue was rendered moot by the Court's finding that the respondent is not entitled to disability benefits. The Court's primary focus was on the proper application of the POEA-SEC and the mandatory procedure for resolving conflicting medical opinions. On the issue of whether the respondent is entitled to attorney's fees: As the respondent was found not entitled to disability benefits, the claim for attorney's fees, which was based on the monetary award, was also dismissed.
Main Doctrine
The referral to a third doctor is a mandatory procedure in resolving conflicting medical assessments between the company-designated physician and the seafarer's physician. Failure to comply with this mandatory procedure renders the assessment of the company-designated physician final and binding.