De Vera v. United Philippine Lines
REITERATIONFacts
The Antecedents: Petitioner Jan Frederick Pineda De Vera (De Vera) was employed as a Bar Attendant on board a vessel for a period of 10 months. While on duty, De Vera complained of lower back pain. He was medically evaluated and treated, including an MRI which revealed moderate degenerative disc disease. He was repatriated to Manila and referred to company-designated physicians. After undergoing conservative management, physical therapy, and evaluation by an orthopedic spine surgeon, the company-designated physicians issued a final medical summary report on April 2, 2013, declaring De Vera fit to work. Procedural History: On April 18, 2013, De Vera filed a complaint for total and permanent disability benefits, among other claims. Prior to filing the complaint, he received sickness allowance and maintenance pay. On April 22, 2013, he executed a Deed of Release and Quitclaim in favor of the respondents. On July 25, 2013, De Vera obtained a contrary medical opinion from his own physician, Dr. Cesar H. Garcia, who concluded he was unfit to work. The Labor Arbiter ruled in favor of De Vera, awarding disability benefits. The NLRC reversed this, finding the company-designated physicians' assessment more credible and the quitclaim valid. The Court of Appeals affirmed the NLRC ruling. The Petition: De Vera filed a Petition for Review on Certiorari before the Supreme Court, arguing that he is entitled to disability compensation, that the third doctor opinion is merely directory, that the "maximally medically improved" assessment is not a "fit to work" declaration, that his physician's opinion deserves consideration, and that the Deed of Release and Quitclaim was obtained through fraud.
Issue(s)
Whether De Vera is entitled to total and permanent disability compensation. Whether the Deed of Release and Quitclaim was validly executed. Whether De Vera is entitled to attorney's fees.
Ruling
The petition is denied. The Court affirmed the decision of the Court of Appeals, upholding the ruling of the NLRC that De Vera is not entitled to total and permanent disability compensation. The Deed of Release and Quitclaim was deemed valid, and consequently, De Vera is not entitled to attorney's fees.
Ratio Decidendi
On the entitlement to total and permanent disability benefits: The Court ruled that De Vera's complaint for total and permanent disability benefits was premature. His employment contract was governed by the 2010 POEA-SEC, which mandates a third doctor's opinion if the seafarer's doctor disagrees with the company doctor. De Vera filed prematurely, before securing a contrary medical opinion. The company doctors had already issued a fit-to-work assessment within the 120-day period. De Vera also failed to comply with the conflict-resolution mechanism under Section 20(A)(3) of the POEA-SEC by not seasonably seeking a second opinion or referring the conflicting findings to a third doctor. His failure to do so meant that the company-designated physicians' findings prevailed. On the validity of the Deed of Release and Quitclaim: The Court held that the Deed of Release and Quitclaim executed by De Vera was valid. While quitclaims are generally viewed with caution, they are recognized as valid if executed voluntarily, with full understanding, and for a credible and reasonable consideration. The Court found no evidence of fraud or deceit in the preparation of the deed. The consideration of ₱40,808.16 was deemed reasonable, especially considering that De Vera had already received substantial amounts as sickness allowance and maintenance pay. By executing the quitclaim, De Vera impliedly admitted the correctness of the company-designated physicians' assessment and waived his right to claim further benefits. On entitlement to attorney's fees: Since De Vera was found not entitled to any disability compensation or other claims, the Court ruled that he was also not entitled to attorney's fees.
Main Doctrine
A seafarer's claim for total and permanent disability benefits is premature if filed before securing a contrary medical opinion from a physician of choice, especially when the company-designated physician has issued a fit-to-work assessment within the prescribed period. Failure to comply with the conflict-resolution procedure under the POEA-SEC, specifically the referral to a third doctor, renders the company-designated physician's assessment prevailing.