In the case of Ruthgar T. Parce v. Magsaysay Maritime Corporation, the Supreme Court clarified the standards for determining a seafarer’s entitlement to disability benefits, emphasizing the necessity of a clear and definitive medical assessment from the company-designated physician. The court ruled that a declaration of ‘maximum medical improvement’ alone does not equate to a fitness-to-work assessment. The ruling reinforces the importance of providing seafarers with proper medical assessments and protecting their rights to claim disability benefits when their ability to work at sea is compromised, ensuring fair treatment and adherence to contractual obligations under the POEA-SEC guidelines.

When Does ‘Maximum Medical Improvement’ Mean Fit to Work? A Seafarer’s Fight for Disability Benefits

Ruthgar T. Parce, a seasoned seafarer, had been employed by Magsaysay Maritime Agency, Inc. since 1992. In 2014, he was working as a Senior Electrical Fitter aboard the vessel ‘Golden Princess’ when he injured his left shoulder while lifting heavy objects. Despite initial treatment and pain management, the pain persisted, leading to his repatriation to the Philippines. Upon his return, Parce underwent treatment with Shiphealth, Inc., the company-designated physician. After several therapy sessions, he was informed that he had reached ‘maximum medical cure,’ and no further treatment would be provided.

However, Shiphealth issued a Final Medical Report indicating a diagnosis of rotator cuff tendinitis but without a clear declaration of Parce’s fitness to return to sea duties. A subsequent Memorandum from Princess Cruises considered Parce fit without restrictions based on this report. Still experiencing pain, Parce consulted another physician, Dr. Manuel Fidel Magtira, who declared him permanently unfit for sea duties. This divergence in medical opinions led Parce to request a referral to a third doctor, which Magsaysay denied. Consequently, Parce filed a complaint seeking disability benefits, arguing that the company-designated physician’s report was incomplete and did not accurately reflect his condition.

The Labor Arbiter ruled in favor of Parce, awarding him full disability benefits and attorney’s fees, a decision affirmed by the National Labor Relations Commission (NLRC). The NLRC emphasized that the company-designated physician’s report did not contain a definite assessment of Parce’s fitness for work, and the failure to provide such an assessment within the prescribed period rendered Parce’s disability total and permanent by operation of law. Magsaysay appealed to the Court of Appeals (CA), which reversed the labor tribunals’ decisions, citing Parce’s failure to immediately protest the medical assessment and a perceived delay in filing his complaint. This divergence in rulings set the stage for the Supreme Court’s intervention to clarify the requirements for determining a seafarer’s disability benefits.

The Supreme Court, in its analysis, emphasized that a seafarer’s entitlement to disability benefits is governed by Philippine laws, particularly Articles 191 to 193 of the Labor Code, and the provisions of the POEA-SEC, which are integrated into every seafarer’s employment contract. The Court highlighted Section 20(A)(3) of the 2010 POEA-SEC, which mandates that a seafarer must submit to a post-employment medical examination by a company-designated physician within three working days of their return. This section also outlines the process for resolving disagreements in medical assessments through a third doctor’s opinion. The Supreme Court stressed the importance of a complete and timely medical report from the company-designated physician in determining disability gradings, citing the Chan v. Magsaysay Maritime Inc. case to reinforce this requirement.

The Court found that the medical report issued by Magsaysay’s company-designated physician fell short of the requirements for a complete and definite assessment. The term ‘maximum medical improvement’ used in the report was deemed insufficient to indicate fitness for sea duty. The Supreme Court clarified that such a term merely suggests that the patient’s treatment has ended but does not equate to a declaration of fitness. Furthermore, the Court noted that Parce was not provided with a copy of the final medical report, which is essential for the seafarer to properly contest and evaluate the medical assessment, as stipulated in the POEA-SEC. This failure to provide a conclusive and definite assessment from the company-designated physician relieved Parce of the burden to initiate a referral to a third doctor, as his disability became permanent by operation of law. In the Salas v. Transmed Manila Corporation, et al. case, it was clearly stated that

The responsibility of the company-designated physician to arrive at a definite assessment within the prescribed period necessitates that the perceived disability rating has been properly established and inscribed in a valid and timely medical report. To be conclusive and to give proper disability benefits to the seafarer, this assessment must be complete and definite; otherwise, the medical report shall be set aside and the disability grading contained therein shall be ignored.

The Supreme Court underscored the importance of providing seafarers with a copy of their final medical report. Quoting Section 20 of the POEA-SEC, the court reiterated that, ‘When requested, the seafarer shall be furnished a copy of all pertinent medical reports or any records at no cost to the seafarer.’ Citing Gere v. Anglo-Eastern Crew Management Phils., Inc., the Court emphasized that denying a seafarer the opportunity to evaluate their medical assessment invalidates the report. In light of these considerations, the Supreme Court reversed the Court of Appeals’ decision, reinstating the NLRC’s ruling that Magsaysay Maritime Corporation and Princess Cruises Ltd. were jointly and severally liable to pay Ruthgar T. Parce permanent disability benefits.

The Court affirmed the award of attorney’s fees, finding it justified under Article 2208 of the New Civil Code, as Parce was compelled to litigate to pursue his disability benefits. However, the claims for moral and exemplary damages were denied due to a lack of substantial evidence showing that Magsaysay and Princess Cruises acted with malice or bad faith. The Supreme Court’s decision clarified the interpretation of ‘maximum medical improvement’ in seafarer disability claims, underscoring the necessity of a clear, definite, and communicated assessment of fitness to work from the company-designated physician.

FAQs

What was the key issue in this case?	The key issue was whether the medical report issued by the company-designated physician, indicating “maximum medical improvement” without a clear statement of fitness to work, was sufficient to deny the seafarer’s claim for disability benefits.
What does “maximum medical improvement” mean?	“Maximum medical improvement” means that the seafarer has reached the point where further medical treatment will not significantly improve their condition, but it does not necessarily mean they are fit to return to work.
What is the role of the company-designated physician?	The company-designated physician is responsible for providing a complete and definite assessment of the seafarer’s medical condition, including a clear statement of fitness to work or a disability rating.
What happens if the seafarer disagrees with the company doctor?	If the seafarer disagrees with the company doctor’s assessment, they can consult their own physician, and if there is still disagreement, a third, independent doctor can be jointly chosen to provide a final and binding opinion.
What is the POEA-SEC?	The POEA-SEC (Philippine Overseas Employment Administration-Standard Employment Contract) is a standard employment contract that governs the rights and obligations of Filipino seafarers and their employers.
What is the significance of Section 20(A)(3) of the POEA-SEC?	Section 20(A)(3) of the POEA-SEC outlines the procedures and timelines for medical examinations and assessments of seafarers who suffer work-related injuries or illnesses, including the process for resolving disputes in medical opinions.
Can a seafarer claim disability benefits even without a third doctor’s opinion?	Yes, if the company-designated physician fails to provide a complete and definite assessment of the seafarer’s fitness to work within the prescribed period, the seafarer’s disability may be considered permanent by operation of law, entitling them to benefits without needing a third doctor.
What did the Supreme Court rule regarding attorney’s fees in this case?	The Supreme Court affirmed the award of attorney’s fees to the seafarer, as he was compelled to litigate to pursue his rightful disability benefits.

This case highlights the importance of clear and definitive medical assessments for seafarers seeking disability benefits. The Supreme Court’s ruling reinforces the obligation of employers to ensure that company-designated physicians provide comprehensive reports and that seafarers are informed of their medical status, ultimately protecting the rights of Filipino seafarers under the POEA-SEC.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Ruthgar T. Parce v. Magsaysay Maritime Corporation, G.R. No. 241309, November 11, 2021