Reuyan v. Inc Navigation Co. Phils., Inc.
REITERATIONFacts
The Antecedents: Petitioner Warren A. Reuyan was employed as an Ordinary Seaman by respondent INC Navigation Co. Phils., Inc. for a seven (7)-month contract. In February 2016, while on board M/V Jork Valiant, he developed an enlarging mass on his neck, which was later diagnosed in Athens, Greece, as a "palpable mass at approximately 4 cm the right side of the thyroid gland pain on palpation" and "enlarged node approximately 3.5 cm of the thyroid gland at the right side complicated by bleeding," recommending thyroidectomy. He was medically repatriated on March 13, 2016, and subsequently diagnosed with papillary thyroid carcinoma after surgery. Petitioner alleged that the company-designated physician recommended radiation therapy on September 2, 2016, but this treatment was discontinued by respondents. He then sought an independent assessment from Dr. Emmanuel Trinidad, who declared him unfit for sea duty and his illness work-related/aggravated, leading him to file a complaint for disability benefits. Respondents denied the claims, asserting the illness was not work-related and that petitioner received extensive treatment from company-designated physicians for 169 days, but their medical assessment dated September 23, 2016, affirmed the illness was not work-related. Procedural History: The Labor Arbiter (LA) ruled in favor of petitioner, finding him suffering from a work-related permanent and total disability, and ordered respondents to pay US$60,000.00 in disability benefits plus 10% attorney's fees. The LA found a reasonable work connection and noted respondents' failure to initiate a third doctor referral. However, the LA denied claims for sickness allowance, moral, and exemplary damages. The National Labor Relations Commission (NLRC) reversed the LA's ruling, finding that petitioner failed to prove his illness was work-related and that the company-designated physicians' examination and treatment were more extensive. Petitioner's motion for reconsideration was denied. The Court of Appeals (CA) affirmed the NLRC's ruling, finding no grave abuse of discretion, holding that respondents presented evidence to rebut the disputable presumption of work-relatedness and that petitioner failed to prove his working conditions caused or aggravated his illness. Petitioner's motion for reconsideration was denied by the CA. The Petition: Petitioner Warren A. Reuyan filed a petition for review on certiorari under Rule 45 of the Rules of Court before the Supreme Court, assailing the Decision dated June 28, 2019, and the Resolution dated October 24, 2019, of the Court of Appeals. Petitioner argued that the CA erred in not ascribing grave abuse of discretion on the part of the NLRC when the latter tribunal ruled that he was not entitled to permanent and total disability benefits, essentially challenging the lower courts' findings regarding the work-relatedness of his illness and the application of the 120/240-day rule for disability assessment.
Issue(s)
Whether or not the Court of Appeals (CA) correctly ruled that the National Labor Relations Commission (NLRC) did not gravely abuse its discretion in holding that petitioner was not entitled to total and permanent disability benefits.
Ruling
The petition is PARTLY GRANTED. The Decision dated June 28, 2019, and the Resolution dated October 24, 2019, of the Court of Appeals in CA-G.R. SP No. 153375, which affirmed the Decision dated June 28, 2017, and the Resolution dated August 31, 2017, of the National Labor Relations Commission in NLRC LAC No. (OFW-M) 04-000308-17, are hereby REVERSED and SET ASIDE. The Decision dated January 12, 2017, of the Labor Arbiter in NLRC NCR Case No. OFW (M) 10-13058-16 is REINSTATED with MODIFICATION, in that petitioner Warren A. Reuyan is awarded total and permanent disability benefits amounting to the Philippine currency equivalent of US$60,000.00, plus ten percent (10%) attorney's fees amounting to US$6,000.00. The same shall earn legal interest at the rate of six percent (6%) per annum from finality of this Decision until full payment.
Ratio Decidendi
On Issue 1: The Supreme Court found that the Court of Appeals erred in not ascribing grave abuse of discretion on the part of the National Labor Relations Commission. The Court applied the established guidelines from Pelagio v. Philippine Transmarine Carriers, Inc., which mandate that a company-designated physician must issue a final and definite assessment of a seafarer's disability rating within 120 days, extendable to 240 days with proper justification. In this case, the 17 medical reports issued by the company-designated physician did not state whether petitioner was already fit to work or had been assessed with a certain disability grading; they merely contained findings, diagnoses, medications, and next appointments. Crucially, respondents discontinued the recommended radioactive iodine treatment, thus precluding the company-designated physicians from issuing a final and definite assessment required by law. Consequently, the Court held that the failure of the company-designated physicians to issue a final and definite assessment within the prescribed periods gave rise to a conclusive presumption that petitioner indeed sustained a work-related permanent and total disability, entitling him to the corresponding benefits. This strict adherence to the mandatory assessment period is essential to determine the true extent of a seafarer's injury and their capacity to resume work, and non-compliance renders the disability total and permanent by operation of law, in line with the general policy of our laws to afford protection to labor.
Main Doctrine
The Supreme Court reiterates the strict application of the 120/240-day rule for seafarers' claims for permanent and total disability benefits. This doctrine mandates that the company-designated physician must issue a final and definite medical assessment of the seafarer's disability grading within 120 days from repatriation, extendable to 240 days with sufficient justification. Failure to issue such a final assessment within these prescribed periods, regardless of ongoing treatment or its discontinuation by the employer, leads to a conclusive presumption that the seafarer's disability is permanent and total by operation of law, thereby entitling them to corresponding benefits. This rule underscores the protective policy of labor laws, ensuring that seafarers are not left in limbo regarding their medical condition and compensation.