Horlador v. Philippine Transmarine Carriers, Inc.
REITERATIONFacts
The Antecedents: Petitioner Ariel P. Horlador was hired as a Chief Cook on board the vessel PRAIA. While on board, he experienced severe pain in his waist, abdomen, and left scrotum. He was diagnosed with "infection with the need to rule out Epididymitis and Prostatitis" and advised to undergo repatriation. Upon arrival in the Philippines, petitioner claimed he reported to respondent Philippine Transmarine Carriers, Inc. (PTCI) for further treatment but was ignored. He sought treatment using his health card and was diagnosed with hernia. Two other physicians concluded that his "Chronic prostatitis" permanently and totally prohibited him from working as a seaman. Petitioner filed a complaint for permanent and total disability benefits. Procedural History: The Labor Arbiter dismissed the complaint. The National Labor Relations Commission (NLRC) reversed the LA's ruling, ordering respondents to pay petitioner permanent and total disability benefits and attorney's fees. The Court of Appeals (CA) affirmed the NLRC ruling but deleted the award of attorney's fees, finding no factual basis for it. The CA held that the NLRC did not gravely abuse its discretion in finding that petitioner suffered a compensable work-related illness causing permanent and total disability and that respondents denied his request for treatment or post-employment medical examination. The Petition: The Petition assails the CA's deletion of the award of attorney's fees.
Issue(s)
Whether the Court of Appeals correctly deleted the award of attorney's fees in petitioner's favor.
Ruling
The petition is meritorious. The Court modified the decision of the Court of Appeals by reinstating the award of attorney's fees equivalent to ten percent (10%) of the total monetary awards due petitioner Ariel P. Horlador.
Ratio Decidendi
On the issue of attorney's fees: The Court held that the CA erred in deleting the award of attorney's fees. Attorney's fees can be awarded in their extraordinary concept as indemnity for damages. Article 2208 of the Civil Code enumerates instances when attorney's fees may be recovered, including cases where the defendant acted in gross and evident bad faith in refusing to satisfy a plainly valid claim, or in actions for indemnity under workmen's compensation and employer's liability laws. In labor cases involving employees' wages and other benefits, it is consistent jurisprudence that when an employee is entitled to the benefits prayed for, he/she is also entitled to attorney's fees amounting to ten percent (10%) of the total monetary award. This is because the employee is compelled to litigate to protect his/her valid claim. In this case, petitioner was found to be entitled to permanent and total disability benefits, and he was forced to litigate to protect this valid claim, thus warranting the award of attorney's fees.
Main Doctrine
In labor cases involving employees' wages and other benefits, when the concerned employee is entitled to the wages/benefits prayed for, he/she is also entitled to attorney's fees amounting to ten percent (10%) of the total monetary award due him/her, as the employee is forced to litigate to protect his/her valid claim.