Sharp Crew Management v. Jaicten
REITERATIONFacts
The Antecedents: Respondent Jimmy G. Jaicten (Jaicten) was employed as a Bosun by C.F. Sharp Crew Management for its foreign principal James Fisher Tankship, Ltd. (JFTL). During his pre-employment medical examination, he was declared fit to work. On October 5, 2008, he suffered chest pains and was diagnosed with non-ST myocardial infarction, undergoing coronary arteriography and stenting. He was repatriated on October 30, 2008. Procedural History: The company-designated physician declared Jaicten fit to work on January 7, 2009. Jaicten sought a second opinion from Dr. Efren Vicaldo, who declared him unfit to resume sea duties. Jaicten filed a complaint for disability benefits. The Labor Arbiter (LA) dismissed the complaint, finding Jaicten not entitled to benefits as he signed a Certificate of Fitness to Work and was lined up for re-employment. The National Labor Relations Commission (NLRC) reversed the LA, granting disability benefits based on Dr. Vicaldo's opinion, which it found consistent with the company-designated physician's recommendation for continued medication. The Court of Appeals (CA) affirmed the NLRC ruling, giving more weight to Dr. Vicaldo's opinion and considering the company-designated doctors' findings biased. The CA also noted that Jaicten's prolonged non-deployment despite being declared fit cast doubt on his fitness. The Petition: Petitioners C.F. Sharp Crew Management and JFTL challenged the CA's decision, arguing Jaicten was not entitled to permanent and total disability benefits.
Issue(s)
Whether Jaicten is entitled to permanent and total disability benefits and attorney's fees. Whether the assessment of the company-designated physician should prevail over the seafarer's physician, and the effect of the Certificate of Fitness to Work.
Ruling
The Petition is GRANTED. The January 22, 2013 Decision and August 30, 2013 Resolution of the Court of Appeals are REVERSED and SET ASIDE. The May 6, 2010 Decision of the Labor Arbiter dismissing the complaint is REINSTATED and AFFIRMED.
Ratio Decidendi
On the entitlement to permanent and total disability benefits and attorney's fees: The Court found that Jaicten is not entitled to permanent and total disability benefits, primarily based on the company-designated physician's assessment. This assessment was supported by extensive examinations and diagnostic tests over three months, declaring Jaicten fit to resume sea duties. The medical opinion of Dr. Vicaldo, who saw Jaicten only once and did not perform diagnostic tests, was given less weight. The Court reiterated that the company-designated physician's assessment, when thorough, is generally given greater weight. Dr. Vicaldo did not declare Jaicten entitled to permanent and total disability benefits, but only to Grade VII disability. Jaicten also failed to comply with the third-doctor referral procedure. The Court also considered Jaicten's attempt to seek re-employment, contradicting his disability claim. Attorney's fees are not warranted as Jaicten failed to prove bad faith on the part of the petitioners, who provided medical treatment and acted on the company-designated physician's assessment. On whether the assessment of the company-designated physician should prevail over the seafarer's physician, and the effect of the Certificate of Fitness to Work: The Court held that the company-designated physician's assessment should prevail, given its thoroughness. Furthermore, Jaicten's signing of the Certificate of Fitness to Work effectively released the petitioners from liability. Absent evidence of coercion, Jaicten is bound by its conditions. His claim that he signed it believing he would be re-deployed was unsupported. Seafarers are not covered by the definition of "regular employment" under Article 280 of the Labor Code, meaning petitioners were not obligated to rehire Jaicten. Therefore, his subsequent non-deployment should not be held against the petitioners.
Main Doctrine
The assessment of the company-designated physician on a seafarer's fitness to work or degree of disability generally prevails over the opinion of a seafarer's chosen physician, especially when the company physician's assessment is based on extensive examinations and monitoring, and the seafarer's physician's opinion lacks sufficient diagnostic support. Furthermore, signing a Certificate of Fitness to Work, absent any showing of coercion, binds the seafarer to its conditions and may release the employer from liability.