Mangubat v. Dalisay Shipping Corporation
REITERATIONFacts
1. The Antecedents: Petitioner Celso S. Mangubat, Jr., a seafarer, sustained a depressed fracture of the lateral tibial plateau of his right leg while performing maintenance work on a vessel. He underwent surgery and rehabilitation, with the company-designated physician eventually declaring him fit to work after noting his restored range of motion, ability to bear weight without pain, and absence of swelling or instability. However, a medical certificate from a private hospital indicated he still required further physical therapy for a year due to muscle atrophy. 2. Procedural History: Following his repatriation and treatment, petitioner sought disability benefits. His request for referral to a third doctor during conciliation proceedings was denied. He subsequently filed a complaint with the Labor Arbiter (LA), who dismissed the case, finding him not entitled to disability benefits based on the company-designated physician's assessment of fitness to work. The National Labor Relations Commission (NLRC) affirmed the LA's decision but awarded financial assistance. The Court of Appeals (CA) dismissed petitioner's subsequent petition for certiorari, upholding the NLRC's findings. 3. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's dismissal of his petition for certiorari. He argues that the failure to refer the case to a third doctor should be held against the respondents. The core of his argument is that the CA erred in upholding the NLRC's and LA's findings, which relied on the company-designated physician's assessment, despite his own doctor's contrary opinion and the alleged invalidity of the referral process.
Issue(s)
Whether the Court of Appeals correctly dismissed the petition for certiorari. Whether petitioner is entitled to disability benefits.
Ruling
The Petition is denied. The Resolutions dated April 19, 2016 and August 15, 2016 of the Court of Appeals in CA-G.R. SP No. 142820 are affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals correctly dismissed the petition for certiorari: The Court held that the CA acted correctly in dismissing the petition for certiorari. A petition for certiorari is limited to correcting errors of jurisdiction and does not include the correction of the NLRC's evaluation of evidence. The CA found that the NLRC's act of sustaining the LA Decision did not constitute grave abuse of discretion, as it was based on a painstaking review of the evidence. The factual findings of the NLRC, when coinciding with those of the LA and supported by substantial evidence, are accorded great respect and finality. Therefore, the CA's dismissal of the petition for certiorari was proper. On the issue of whether petitioner is entitled to disability benefits: The Court affirmed the rulings of the LA, NLRC, and CA that the petitioner was not entitled to disability benefits. This was based on the assessment of the company-designated physician that the petitioner was fit to work. For the seafarer to dispute the company-designated physician's assessment, the seafarer's own doctor must provide a definite and conclusive assessment of fitness to work or degree of disability. In this case, the petitioner's doctor issued a certification stating he was "Unfit to work for a year yet. Needs physical therapy because of muscle atrophy." The Court found this assessment to be indefinite and invalid because it failed to state the seafarer's fitness to work or indicate his disability grade. Consequently, the definite and valid assessment of the company-designated physician stands and is binding on the seafarer. The failure of the respondents to heed the request for a third doctor during conciliation was not taken against them because the petitioner's own doctor's assessment was invalid.
Main Doctrine
The assessment of the company-designated physician is binding if the seafarer's own doctor fails to provide a definite and conclusive assessment of fitness to work or degree of disability, thereby invalidating the seafarer's claim for disability benefits.