Maersk v. Ramos
REITERATIONFacts
1. The Antecedents: Respondent Joselito R. Ramos was employed as an able-seaman by Maersk Filipinas Crewing Inc. and Maersk Co. IOM Ltd. On November 14, 2001, while on board the vessel, his left eye was struck by a screw, leading to a diagnosis of corneal scar and cystic macula. Despite undergoing medical treatment and surgery, including cataract extraction, his vision in the left eye remained impaired. Following the rejection of his claim for disability benefits, Ramos filed a complaint for total permanent disability, illness allowance, moral and exemplary damages, and attorney's fees. 2. Procedural History: The Labor Arbiter initially dismissed Ramos's complaint, finding it prematurely filed and directing continued medical assistance until fitness to work or disability was assessed. Ramos attempted to file an appeal with the National Labor Relations Commission (NLRC), but due to a jeepney strike, his appeal was filed slightly late. The NLRC granted the appeal, setting aside the Labor Arbiter's decision and ordering the petitioners to pay disability compensation, damages, and attorney's fees, finding the appeal to have been perfected in the interest of fairness. The NLRC's resolution was affirmed by the Court of Appeals (CA), with the modification of deleting the awards for moral and exemplary damages due to insufficient factual basis. Petitioners' motion for reconsideration was denied by the CA. 3. The Petition: Petitioners Maersk Filipinas Crewing Inc. and Maersk Co. IOM Ltd. filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA's decision. They argued that Ramos's counsel lacked authority to represent him after the Labor Arbiter's decision and that the appeal to the NLRC was not perfected within the reglementary period. Furthermore, they contended that Ramos was not entitled to disability compensation as his injury was considered curable and did not meet the threshold for permanent partial disability under the POEA Standard Employment Contract. The Supreme Court denied the petition, affirming the CA's decision, holding that the counsel's authority was presumed, the appeal was deemed perfected in the interest of substantial justice, and Ramos was entitled to disability compensation for permanent partial disability due to the impairment of his earning capacity.
Issue(s)
Whether counsel of respondent was authorized to represent the latter after the LA had rendered its Decision on 15 May 2003; Whether respondent perfected his appeal to the NLRC; Whether respondent is partially disabled and therefore entitled to disability compensation.
Ruling
The Supreme Court denied the Petition for Review on Certiorari, affirming the Decision and Resolution of the Court of Appeals. The Court ruled that the respondent's counsel is presumed to have the authority to represent him, that the appeal was deemed perfected despite the slight delay due to circumstances beyond the respondent's control, and that the respondent is entitled to permanent partial disability compensation.
Ratio Decidendi
On the authority of counsel: The Court reiterated the presumption under Section 21, Rule 138 of the Rules of Court that an attorney is properly authorized to represent a client in all stages of litigation. This presumption is strong and can only be overcome by compelling evidence, not by a mere denial, especially when such denial comes after an adverse judgment. The respondent's manifestation disclaiming his counsel's authority, filed years after the LA's decision and after a favorable NLRC ruling, lacked cogent reason and evidence, thus failing to overcome the presumption. The Court found it suspicious that the respondent would renounce his counsel's authority at such a late stage, particularly when it would serve the petitioners' interest in avoiding liability. On the perfection of appeal: The Court agreed with the NLRC and CA that the respondent had substantially perfected his appeal. While the appeal was filed by registered mail on the day after the deadline, this was due to circumstances beyond the respondent's control, namely, the NLRC NCR closing early because of a jeepney strike. The NLRC's decision to grant the appeal until the next working day was deemed just and fair, aligning with the Court's prerogative to relax procedural rules in the interest of due process and speedy disposition of justice. The Court emphasized that procedural rules, even those of a mandatory character, may be relaxed when strict adherence would result in a miscarriage of justice. On entitlement to disability compensation: The Court affirmed that the respondent suffers from permanent partial disability and is entitled to compensation. The Court reiterated that disability, in labor law, refers to the loss or impairment of earning capacity, not merely the injury or pain. While the company-designated physician eventually certified the respondent as fit to work with correctional glasses, he had previously acknowledged that the left eye could no longer be improved by medical treatment and assessed it as 30% disabled. The curability of the injury does not preclude compensation if it incapacitates the seafarer from performing his customary work. The fact that the respondent was not offered re-employment despite the company physician's assessment further supports his claim of lost earning capacity. The Court also clarified that the POEA Standard Employment Contract's disability schedule is not exclusive, and the respondent's Grade 12 impediment, calculated at 10.45% of the maximum compensation, was correctly awarded based on the CBA provisions and the company physician's assessment of 30% disability.
Main Doctrine
A seafarer suffering from permanent partial disability, even if the injury is curable or can be corrected with medical intervention, is entitled to disability compensation if the disability incapacitates him from performing his customary work. The curability of the injury does not preclude an award for disability because, in labor laws, disability need not render the seafarer absolutely helpless or feeble to be compensable; it is enough that it incapacitates him to perform his customary work. Furthermore, the presumption of authority of counsel to represent a party in all stages of litigation is strong and can only be overcome by compelling evidence.