Lacson v. RCCL Crew Management Inc.
REITERATIONFacts
1. The Antecedents: Charlonne Keith Lacson, a seafarer employed as AZ Commis 2, alleged that his work exposed him to cleaning materials, sanitizers, bleaches, acids, degreasers, and detergents, leading to the development of allergic dermatitis, diagnosed by a shore physician in Italy. Upon repatriation, he was diagnosed with Contact Dermatitis with Secondary Bacterial Infection by the company-designated physician, Shiphealth, Inc. Despite ongoing treatment, his skin condition persisted, leading to diagnoses of Hand Dermatitis RIO Allergic Contact Dermatitis and Dyshidrotic Eczema and Nummular Eczema by other physicians, who declared him unfit for duty in the kitchen. 2. Procedural History: Petitioner filed a complaint for permanent and total disability benefits. The Labor Arbiter dismissed the complaint for failure to comply with the third-doctor rule and found no merit in the claim of no final and definite assessment, deeming Shiphealth's findings final and binding. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. Subsequently, the Court of Appeals (CA) dismissed the petition, holding that the claim for permanent and total disability had no factual or legal basis, and that Shiphealth's medical assessment was valid, final, and definite. The CA found no proof that the petitioner's condition amounted to permanent total disability or that he was still suffering from the skin disease. 3. The Petition: This Petition for Review on Certiorari seeks to annul the CA's decision and resolution. Petitioner argues that courts are not bound by the company-designated physician's findings if not supported by medical records, and that the Final Report from Shiphealth was invalid due to an undisclosed signatory and unclear assessment. Petitioner also contends that his condition became permanent and total by operation of law as the Final Report was issued beyond the 240-day period and lacked a definitive statement of fitness for work. The petition further asserts that the illness is work-related, disputing the claim of a pre-existing condition and highlighting the lack of a definitive medical assessment within the prescribed periods, thus entitling him to permanent disability benefits.
Issue(s)
Whether the petitioner is entitled to permanent and total disability benefits. Whether the medical assessment of the company-designated physician was final and definite. Whether the petitioner's illness is work-related. Whether the petitioner complied with the third-doctor rule.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. Respondents are jointly and severally liable to pay petitioner Charlonne Keith Lacson USD 60,000.00 or its equivalent in Philippine currency, plus 10% attorney's fees and legal interest.
Ratio Decidendi
On the entitlement to permanent and total disability benefits: The Court found that the petitioner is entitled to permanent and total disability benefits. This entitlement arose by operation of law due to the company-designated physician's failure to issue a final and definite medical assessment within the prescribed periods. The Final Report issued by Shiphealth was addressed to the Crew Medical Case Manager, not to the petitioner, and there was no proof of its timely furnishing to him. This failure to provide a clear and definite assessment, coupled with the lack of proof of timely notice, meant that the petitioner's disability became permanent and total by operation of law. On the finality and definiteness of the company-designated physician's assessment: The Court ruled that Shiphealth's Final Report dated January 17, 2019, was not valid, final, and definite. The report failed to provide a declaration as to the petitioner's capacity to return to work or a categorical degree of disability. Furthermore, the report was addressed to the employer's representative, not the seafarer, and there was no evidence that it was furnished to the petitioner within the prescribed periods. The Crew Fit for Duty Notice dated January 24, 2019, was also not considered valid as it was not issued by Shiphealth and lacked the name of the examining specialist. On the work-relatedness of the petitioner's illness: The Court found that the petitioner's nummular eczema was work-related. The petitioner's work as AZ Commis 2 involved exposure to cleaning materials like sanitizers, bleaches, acids, degreasers, and detergents. The Court noted that nummular eczema can be triggered by direct exposure to cleaning agents and chemicals, as well as stress and climate changes, all present in the seafarer's working environment. The respondents failed to controvert the work-relatedness of the illness, and the petitioner's pre-employment disclosure of specific allergies (latex and nickel) did not preclude the work-relatedness of his subsequent condition. On compliance with the third-doctor rule: The Court held that there was no need for the petitioner to initiate the referral to a third doctor. This is because the company-designated physician failed to issue a valid, final, and definite assessment. The third-doctor rule is applicable only when there is a conflict between the assessments of the company-designated physician and the seafarer's physician, and such conflict arises from a valid and definite assessment by the company doctor. Since Shiphealth's assessment was deemed invalid, the prerequisite for invoking the third-doctor rule was not met.
Main Doctrine
The failure of the company-designated physician to issue a final and definite medical assessment within the prescribed periods, or to properly furnish the seafarer with a copy of such assessment, results in the seafarer's disability being deemed permanent and total by operation of law, entitling them to the maximum disability benefits.