Ville v. Maersk-Filipinas Crewing
REITERATIONFacts
The Antecedents: Gerardo U. Ville (Ville) was hired as Chief Cook by Maersk-Filipinas Crewing, Inc. (Maersk) for its foreign principal, A.P. Moller A/S, for a six-month contract. He underwent a Pre-Employment Medical Examination (PEME) and was declared fit for work. Upon completion of his contract and repatriation on March 1, 2012, Ville did not report any illness or injury sustained during his employment. However, during a subsequent PEME on March 7, 2012, for re-employment, Ville disclosed a history of hypertension and was diagnosed with Coronary Artery Disease, rendering him unfit for sea duty. Believing his condition was work-related, Ville filed a complaint for disability benefits, medical expenses, and damages. Procedural History: The Labor Arbiter ruled in favor of Ville, finding his illness to be work-related and compensable, and ordered the respondents to pay disability benefits and attorney's fees. The National Labor Relations Commission (NLRC) affirmed this decision, holding that Ville had effectively proven his illness was compensable and that his failure to undergo a post-employment medical examination within three days was justified. The respondents appealed to the Court of Appeals (CA), which reversed the NLRC's ruling, finding that Ville's illness was not proven to be work-related or to have existed during his contract term, and that he failed to comply with the mandatory reporting requirements. The Petition: Ville filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision and resolution. He argues that the CA erred in finding him not entitled to total and permanent disability benefits due to his failure to undergo the Post Employment Medical Examination and in reversing the judgment for attorney's fees. The core issue is whether Ville is entitled to disability benefits, with the Supreme Court examining his compliance with the POEA-SEC's requirements, particularly the three-day reporting rule for post-employment medical examinations and the necessity of securing a company-designated physician's opinion before consulting his own doctor.
Issue(s)
Whether the Court of Appeals committed serious errors of law in finding that petitioner is not entitled to recover total and permanent disability benefits as he failed to undergo the Post Employment Medical Examination. Whether the Court of Appeals committed serious errors of law in reversing the judgment for attorney's fees.
Ruling
The Petition for Review on Certiorari is DENIED. The assailed December 19, 2014 Decision and April 23, 2015 Resolution of the Court of Appeals in C.A.-G.R. SP No. 130257 are AFFIRMED.
Ratio Decidendi
On the entitlement to total and permanent disability benefits: The Supreme Court affirmed the Court of Appeals' ruling that Ville is not entitled to disability benefits. The Court reiterated that a seafarer's entitlement to disability benefits is governed by the Labor Code, the Amended Rules on Employees' Compensation Commission, and the POEA-SEC. The employment relationship ceases upon completion of the contract, signing off from the vessel, and arrival at the point of hire, as stipulated in Section 18 of the 2010 POEA-SEC. Therefore, any illness acquired or incident that transpires after signing off or expiration of the contract generally does not attach liability to the employer. Even assuming the illness was work-related and acquired during employment, Ville's claim would still fail due to non-compliance with the three-day reportorial requirement under Section 19(H) and Section 20(A)(3) of the 2010 POEA-SEC. The Court emphasized that failure to submit to a post-employment medical examination by a company-designated physician within three working days upon return, unless incapacitated or prevented by the employer, results in forfeiture of the right to claim benefits. Ville was not incapacitated and the respondents were not aware of his ailment, thus he could not claim exceptions. His submission to a PEME on March 7, 2012, four working days after disembarkation on March 1, 2012, was considered a belated submission and insufficient compliance, which is fatal to his case. The Court also noted that Ville prematurely filed his complaint before consulting his own physician and obtaining a medical opinion, and that his doctors did not clarify the causal relationship between his work and his heart ailment. On the issue of attorney's fees: The affirmation of the CA's decision, which reversed the Arbiter's award of attorney's fees, implies that the claim for attorney's fees was also denied.
Main Doctrine
A seafarer's failure to comply with the mandatory three-day reportorial requirement for post-employment medical examination upon repatriation, without valid exceptions, results in the forfeiture of the right to claim disability benefits, even if the illness is proven to be work-related.