Aldaba v. Career Philippines Ship-Management
REITERATIONFacts
The Antecedents: Petitioner Paulino M. Aldaba, employed as a Bosun, sustained a back injury on April 4, 2011, when he was hit by twisted chains while performing his duties. He was examined in Hong Kong and found to have a fractured back, rendering him unfit to work, leading to his repatriation. Upon arrival in Manila, he underwent further examination by a company-designated physician, which revealed a misalignment of his distal sacrum and degenerative changes in his thoracic spine. After 163 days of treatment, the company physician assessed his disability as Grade 8, indicating a two-thirds loss of motion or lifting power of the trunk. However, petitioner sought an independent assessment, which concluded his injury resulted in permanent disability, rendering him unfit to work as a seafarer. Procedural History: Following the conflicting medical assessments, petitioner demanded total disability compensation, which respondents refused, offering only compensation for a Grade 8 disability. Aggrieved, petitioner filed a complaint for total and permanent disability benefits with the NLRC. The Labor Arbiter initially ruled in favor of the respondents, awarding US$16,795.00 for a Grade 8 disability. Upon appeal, the NLRC reversed this decision, granting petitioner US$60,000.00 for permanent total disability and attorney's fees. The respondents then filed a petition for certiorari with the Court of Appeals (CA), which reversed the NLRC's decision and reinstated the Labor Arbiter's ruling. This led to the present petition before the Supreme Court. The Petition: Petitioner seeks a reversal of the CA's decision, arguing that the CA erred in ruling that he is not entitled to permanent and total disability benefits and in solely giving credence to the company physician's certification over his own doctor's findings. He contends that his inability to perform his job for more than 120 days entitles him to permanent and total disability benefits, citing established jurisprudence. He also asserts that the law does not exclusively vest the authority to assess disability with the company-designated physician and that he is entitled to damages and attorney's fees due to the respondents' alleged bad faith. The respondents, conversely, argue that the 240-day rule should govern and that petitioner's failure to submit conflicting assessments to a third doctor bars his claim.
Issue(s)
Whether the petitioner is entitled to permanent and total disability benefits. Whether the Court of Appeals erred in solely giving credence to the certification of the company physician without considering the findings of the petitioner's doctor of choice.
Ruling
The Supreme Court granted the petition, reversed the Court of Appeals' decision, and reinstated the National Labor Relations Commission's ruling, awarding petitioner total and permanent disability benefits amounting to US$60,000.00, with the modification of omitting the award of attorney's fees.
Ratio Decidendi
On the entitlement to permanent and total disability benefits: The Court held that the company-designated physician issued the final medical assessment on the 163rd day, which is beyond the 120-day period prescribed by law and the POEA Standard Employment Contract (POEA-SEC), without any justifiable reason. The employer has the burden to prove justification for extending the period, which they failed to do. Consequently, the petitioner's disability is deemed permanent and total. The Court reiterated the guidelines established in Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr., emphasizing that the company-designated physician must issue a final assessment within 120 days, and failure to do so without justification leads to permanent and total disability. The period can only be extended to 240 days with sufficient justification, and failure to assess within the extended period also results in permanent and total disability. On giving credence to the company physician's certification: The Court found that the company-designated physician's assessment was issued beyond the mandatory 120-day period without justification. Therefore, the assessment itself, even if it provided a Grade 8 disability rating, could not defeat the petitioner's claim for permanent and total disability, which arose by operation of law due to the delay. The Court noted that while the law recognizes the company-designated physician's role, their assessment must be made within the prescribed periods. The petitioner's independent medical assessment, while not solely determinative, supported his claim, especially given the company physician's failure to comply with the procedural timelines.
Main Doctrine
The company-designated physician must issue a final medical assessment on the seafarer's disability grading within 120 days from the time the seafarer reported to him. Failure to do so without justifiable reason results in permanent and total disability. The period may be extended to 240 days only with sufficient justification, and failure to assess within the extended period also results in permanent and total disability.