Career Philippines v. Godinez

G.R. No. 206826 · 2017-10-02 · J. DEL CASTILLO, J.: · Primary: Labor; Secondary: Civil

REITERATION

Facts

The Antecedents: Eduardo J. Godinez (Godinez) was hired as a Deck Cadet by Career Philippines Shipmanagement, Inc. (Career) for its foreign principal Columbian Shipmanagement, Ltd. (Columbian). He underwent a pre-employment medical examination (PEME) and was declared fit to work. During his employment, Godinez exhibited erratic behavior, including failing to wake up for duty, being verbally abusive, and wandering the ship. Reports were sent to Career detailing his deteriorating condition. Upon arrival in Egypt, he was medically examined and repatriated. A company-designated medical facility, Sachly International Health Partners, Inc. (Sachly), diagnosed him with bipolar disorder. An unsigned medical report from Sachly noted his admission of past insomnia and paranoia episodes. Another report recommended considering bipolar disorder II, noting erratic sleeping patterns and verbal abuse. Godinez was admitted to UST Hospital for further tests. Sachly issued a report confirming bipolar disorder, stating it was not an occupational illness. Godinez signed a "Certificate of Fitness for Work" on March 12, 2004, witnessed by Dr. Susannah Ong-Salvador of Sachly, releasing Career and Columbian from all liabilities. All medical expenses prior to this certification were paid, and he received sickness allowance. Godinez was denied re-employment. An independent specialist, Dr. Randy Dellosa, diagnosed him with bipolar disorder and declared him unfit to work. Procedural History: Godinez filed a labor case seeking disability benefits, sickness allowance, medical expenses, damages, and attorney's fees. The Labor Arbiter ruled in favor of Godinez, finding his bipolar disorder work-connected and compensable, and awarding disability benefits, sickness allowance, medical expenses, moral and exemplary damages, and attorney's fees. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision with modification, deleting the individual liability of the operations manager. Career and Columbian appealed to the Court of Appeals (CA). The CA affirmed the NLRC's decision with modifications, reducing the medical expenses, moral damages, and exemplary damages. Both parties filed motions for reconsideration, which were denied. This led to the consolidated petitions before the Supreme Court. The Petition: Petitioners Career and Columbian (G.R. No. 206826) assail the CA's affirmation of disability benefits, sickness allowance, and medical expenses, arguing fraudulent concealment, lack of work-relation, and that Godinez was declared fit to work. They also question the award of damages and attorney's fees due to absence of bad faith. Respondent Godinez (G.R. No. 206828) questions the CA's reduction of damages.

Issue(s)

Whether the Labor Arbiter had jurisdiction over the case. Whether Godinez's bipolar disorder is a work-related illness compensable under the POEA Standard Employment Contract. Whether Godinez committed fraudulent concealment by failing to disclose his past history of insomnia and paranoia. Whether the "Certificate of Fitness for Work" signed by Godinez bars his claim for disability benefits. Whether Godinez suffered permanent and total disability. Whether Godinez is entitled to sickness allowance and reimbursement of medical expenses. Whether Godinez is entitled to moral damages, exemplary damages, and attorney's fees; and whether the CA erred in reducing the monetary awards for medical expenses, moral damages, and exemplary damages.

Ruling

The Court resolves to DENY the Petitions in G.R. No. 206826 and G.R. No. 206828. The May 22, 2012 Decision of the Court of Appeals in CA-G.R. SP No. 105602 is AFFIRMED WITH MODIFICATION, in that INTEREST is hereby imposed upon the total monetary award at the rate of six percent (6%) per annum from the date of finality of this judgment until full satisfaction. WHEREFORE, the Court resolves to DENY the Petitions in G.R. No. 206826 and G.R. No. 206828. The May 22, 2012 Decision of the Court of Appeals in CA-G.R. SP No. 105602 is AFFIRMED WITH MODIFICATION, in that INTEREST is hereby imposed upon the total monetary award at the rate of six percent (6%) per annum from the date of finality of this judgment until full satisfaction. SO ORDERED.

Ratio Decidendi

On the jurisdiction of the Labor Arbiter: The Court affirmed the jurisdiction of the Labor Arbiter. Section 10 of R.A. No. 8042 (Migrant Workers and Overseas Filipinos Act of 1995) clearly grants labor arbiters original and exclusive jurisdiction over claims arising out of employer-employee relationships involving Filipino workers for overseas deployment, including money claims and damages. The CA correctly pointed out that the employer-employee relationship had ceased when the complaint was filed, making Section 31 of the POEA Standard Contract applicable, which mandates that disputes shall be governed by Philippine laws. The respondents' active participation in the proceedings below also estopped them from questioning jurisdiction on appeal. On the work-relatedness and compensability of Godinez's illness: The Court found that Godinez's bipolar disorder was work-related and compensable. The severe psychological trauma and anxiety attacks resulting from the maltreatment by his superior, Second Officer Dayo, aggravated his condition. The Court emphasized that the degree of proof required is substantial evidence and a reasonable work connection, not absolute certainty. The harsh working conditions, including the alleged inhumane treatment, coupled with the lack of timely medical intervention, contributed to his breakdown. The Court noted that psychosocial factors and stressors in the work environment are recognized risk factors for stress-related illnesses. On the defense of fraudulent concealment: The Court rejected the defense of fraudulent concealment. The initial medical report, which supposedly contained Godinez's admission of past insomnia and paranoia, was unsigned and thus lacked evidentiary value. Even if true, the omission was not considered intentional or fraudulent, as the condition occurred when Godinez was only 15 years old and may have simply slipped his mind. Section 20(E) of the POEA contract requires knowing concealment, which was not established. The Court noted that Godinez was young, innocent, and inexperienced at the time of his application. On the "Certificate of Fitness for Work" and its evidentiary value: The Court held that the "Certificate of Fitness for Work" signed by Godinez had no evidentiary value. Godinez, not being a physician, could not competently assess his own health status. The certificate cannot substitute for the company-designated physician's assessment required by law. Dr. Salvador's act of witnessing the certificate, instead of signing a medical report confirming fitness, was deemed unethical and unprofessional conduct, suggesting she could not certify his recovery. On permanent and total disability: The Court affirmed that Godinez suffered permanent and total disability. This was based on the lack of a definite medical assessment by the company-designated physician within the prescribed period. The unsigned March 12, 2004 Medical Progress Report, which supposedly declared him fit, was disregarded due to its unsigned nature. The Court reiterated that permanent total disability means the loss of earning capacity, not absolute helplessness. On monetary awards (sickness allowance, medical expenses): The Court affirmed the award of sickness allowance for the maximum period of 120 days, as Godinez was deemed totally and permanently disabled. However, the reimbursement of medical expenses was reduced to P16,647.85, as only that amount was duly substantiated by receipts. On monetary awards (damages, attorney's fees) and the CA's reduction: The Court found that the employers acted with evident malice and bad faith in fabricating evidence and employing underhanded tactics, thus entitling Godinez to moral and exemplary damages. The CA's reduction of these damages to US$1,000.00 each was affirmed as equitable. Attorney's fees were also deemed warranted due to the necessity of litigation to protect Godinez's rights. The Court denied Godinez's petition to reinstate the higher awards for medical expenses and damages. It found the CA's reduction of medical expenses to be justified due to lack of receipts. While affirming the existence of malice and bad faith, the Court found the CA's reduction of moral and exemplary damages to US$1,000.00 each to be equitable and in line with jurisprudence on deterrence and preventing unjust enrichment.

Main Doctrine

A seafarer's claim for disability benefits is compensable if the illness is work-related and aggravated by the working conditions, even if there is a pre-existing condition, provided there was no fraudulent concealment. A Certificate of Fitness for Work signed by the seafarer, not being a physician, has no evidentiary value to prove fitness for work. Fabricated evidence and underhanded tactics by employers in prosecuting a case evince evident malice and bad faith, entitling the seafarer to moral and exemplary damages.